An Overview of 2023 Inpatient EM Changes in Radiology

March 17, 2023

Physician education is cornerstone to Zotec’s mission, which is to improve the business of healthcare for everyone. Here, we educate radiologists on the nuances of the 2023 inpatient evaluation and management (EM) changes.

Effective on date of service January 1, 2023, the inpatient EM coding guidelines have been updated.  These updates mirror the EM guideline changes implemented in 2021 for office and outpatient EM services.

Hospital Inpatient and Observation Care Services – EM Code Changes

Initial hospital care codes 99221-99233 will represent both inpatient and observation services

  • The CPT Editorial Panel recognizes the similarities in the clinical work between observation and inpatient care.  CMS has adopted the 2023 EM guidelines as published by the AMA/CPT
  • The Hospital Observation codes (99217, 99218, 99220, 99224, 992255, 99226) have been eliminated and merged with the revised inpatient codes (99221-99233) 
Service ProvidedDOS Prior to 2023DOS 2023 and Forward
Observation Care Discharge Services9921799238 (< 30 minutes) or 99239 (> 30 minutes) Does not include admission and discharge on the same date
Initial Observation Care99218, 99218, 9922099221, 99222, 99223
Subsequent Observation Care99224, 99225, 9922699231, 99232, 99233 Depending on MDM or time associated with visit

Determining the EM Level of Service

Hospital inpatient or observation codes will be reported based on Medical Decision Making (MDM) or time

  • History and Physical Exam are no longer a mechanism for determining the EM level.
    • A medically appropriate history and physical exam should be performed and documented by the provider.

Reporting by Time

Reporting using time is now associated with a threshold which the documented time must meet or exceed to report the level of service

The table below represents the required time(s) in minutes to meet or exceed per level of service

EM Service DescriptionTime in Minutes
99221 – Initial care40
99222 – Initial care55
99223 – Initial care75
99231 – Subsequent care25
99232 – Subsequent care35
99233 – Subsequent care50
99234 – Same day initial/discharge45
99235 – Same day initial/discharge70
99236 – Same day initial/discharge85

Reporting by Medical Decision Making (MDM)

Reporting using MDM requires documentation to meet or exceed the same level in at least 2 of the following categories

  • Number and complexity of Problems Addressed at the encounter
  • Data Reviewed/Analyzed
  • Risk

Please reference 2023 Inpatient EM Changes – Documentation Tip Sheet for recommendations and examples.


CPT® Professional Edition 2023

AMA® CPT Symposium 2022

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