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Last Modified: 8/23/2022 Location: FL, PR, USVI Business: Part A, Part B

E/M FAQ -- How does drug therapy differ from drug management?

Q. How does "drug therapy requiring intensive monitoring" differ from "prescription drug management?"
A. Per the CPT definition, "drug therapy requiring intensive monitoring for toxicity" is for a drug requiring intensive monitoring which is a therapeutic agent with the potential to cause serious morbidity or death. The monitoring is performed for assessment of these adverse effects and not primarily for assessment of therapeutic efficacy.
The monitoring should be that which is generally accepted practice for the agent but may be patient specific in some cases. Intensive monitoring may be long-term or short-term. Long-term intensive monitoring is not less than quarterly. The monitoring may be by a lab test, a physiologic test or imaging. Monitoring by history or examination does not qualify. The monitoring affects the level of medical decision making in an encounter in which it is considered in the management of the patient. Examples may include monitoring for a cytopenia in the use of an antineoplastic agent between dose cycles or the short-term intensive monitoring of electrolytes and renal function in a patient who is undergoing diuresis.
"Prescription drug management" is documented evidence the provider has evaluated the patient's medications as part of an E/M service. This may be a prescription being written or discontinued, or a decision to maintain a current medication or dosage. However, simply listing current medications is not considered "prescription drug management."

Monitoring that does not qualify

Examples of monitoring that does not qualify includes:
1. Monitoring by history or examination does not qualify.
2. Monitoring glucose levels during insulin therapy. The primary reason for the monitoring is the therapeutic effect (unless severe hypoglycemia is a current, significant concern), not toxicity levels.
3. Annual monitoring of electrolytes for any reason, as the frequency does not meet the threshold for intensive monitoring.
4. Annual renal function panel for a patient on a diuretic, as the frequency does not meet the threshold for intensive monitoring.

Changes to office/outpatient E/M services for 2021

NOTICE -- Effective for dates of service on and after January 1, 2021, practitioners have the choice to document office and other outpatient E/M visits via medical decision making (MDM) or time. CMS adopted CPT's revised guidance. The E/M code and guideline changes are specific for office and other outpatient visits and apply to codes 99201-99205 and 99211-99215. Based on the CPT changes, code 99201 is no longer valid for dates of service on and after January 1, 2021, as clinicians may choose the E/M visit level based on either medical decision making or time, both CPT code 99201 and 99202 previously require straightforward medical decision making, therefore the decision was made to delete CPT code 99201.
Click here external pdf file to view details regarding the 2021 changes to office or other outpatient E/M services.
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