E/M Level Components: History, Exam, MDM, and Time
Key Takeaways
- Office/outpatient E/M codes 99202-99215 are selected by Medical Decision Making (MDM) OR total time on the date of the encounter.
- History and exam must be medically appropriate but are no longer scoring elements for office/outpatient level selection.
- New-patient codes 99202-99205 require two of three MDM elements; established 99211-99215 also use two of three.
- MDM has three elements: number/complexity of problems, amount/complexity of data, and risk of complications.
Start With the E/M Family
Before leveling, identify the family: office/outpatient, hospital inpatient and observation (merged into 99221-99239), emergency department (99281-99285, which never use time), nursing facility, home/residence, and preventive medicine. Confirm new versus established patient when the family requires it. A new patient has not received professional services from the same physician or group of the same specialty within three years.
MDM and Time for 99202-99215
For office/outpatient visits, CPT directs level selection by Medical Decision Making (MDM) or total time on the date of the encounter. History and exam are documented for clinical reasons but do not score the level. MDM is graded across three elements, and you need two of the three to meet a level:
| MDM level | Code (est.) | Problems | Data | Risk |
|---|---|---|---|---|
| Straightforward | 99212 | Minimal | Minimal/none | Minimal |
| Low | 99213 | Low | Limited | Low |
| Moderate | 99214 | Moderate | Moderate | Moderate |
| High | 99215 | High | Extensive | High |
Time ranges for established patients: 99212 = 10-19 min, 99213 = 20-29 min, 99214 = 30-39 min, 99215 = 40-54 min. Total time counts pre-, intra-, and post-service work on the encounter date (chart review, the visit, documentation, ordering) but excludes time on separately billable procedures.
History and Exam
History and exam still support medical necessity and clinical work. For office/outpatient codes they must be medically appropriate but do not determine the level. In older component-based families or scenarios, a question may still provide history, exam, and MDM and ask for the level under that older rule, so know which logic applies.
Reading the Three MDM Elements
Each MDM element has concrete, testable definitions. The number and complexity of problems addressed counts self-limited problems (minimal), stable chronic illnesses, acute uncomplicated illness (low), one or more chronic illnesses with exacerbation or an acute illness with systemic symptoms (moderate), and a severe exacerbation or an illness posing a threat to life or bodily function (high). The amount and complexity of data counts unique tests ordered or reviewed, independent interpretation of a test, and discussion of management with an external physician, organized into three categories.
Risk considers the management options: over-the-counter drugs are low, prescription drug management is moderate, and decisions about hospitalization, emergency surgery, or drug therapy requiring intensive monitoring are high.
Worked Example
A provider sees an established patient for poorly controlled type 2 diabetes and newly elevated blood pressure. The note documents two chronic illnesses with one exacerbation (moderate problems), review of a hemoglobin A1c plus ordering a basic metabolic panel (limited-to-moderate data), and prescription drug management with a medication adjustment (moderate risk). Two of three elements reach moderate, supporting 99214. If the provider instead documented 35 minutes of total time on the date of service, 99214 is equally supported by time.
Either method works; the coder selects whichever the documentation establishes and the chart should state which was used.
CCA Trap Pattern
Do not pick the highest level just because the note is long. A detailed history and exam paired with low MDM and no qualifying time supports only a low-level code such as 99213. Conversely, do not undercode a visit where prescription drug management and a worsening chronic condition clearly reach moderate MDM. Counting independent interpretation, review of external notes, prescription drug management, and a decision for major surgery can raise MDM, but only when each item is documented and properly counted under CPT rules.
Remember that emergency department codes 99281-99285 are leveled by MDM only and never by time, and that code 99211 does not require physician presence and is used for minimal established-patient visits.
Other E/M Families and Their Rules
Beyond office visits, the CCA expects familiarity with several families. Hospital inpatient and observation care (99221-99223 initial, 99231-99233 subsequent, 99238-99239 discharge) merged observation into the inpatient codes in 2023 and are selected by MDM or total time. Consultations (99242-99245 office, 99252-99255 inpatient) are accepted by some payers but not by Medicare, which directs the work to the appropriate visit code instead. Preventive medicine services (99381-99397) are age-based and are reported separately from a problem-oriented visit with modifier 25 when a significant problem is also addressed.
Critical care (99291-99292) is time-based with a 30-74 minute threshold for the first hour. Knowing the selection method per family prevents applying office rules where they do not belong.
Documentation and Total Time Pitfalls
Total time for office visits counts only the qualifying clinician's time on the date of the encounter, including chart review before, the face-to-face visit, ordering tests, and documenting after, but excluding time spent on a separately reported procedure and excluding staff time. If two clinicians of the same group and specialty both see the patient on the same date, their time is not simply added; only one E/M is reported. A note stating "spent a long time with the patient" does not qualify, while "32 minutes total on the date of service performing E/M work" does.
The exam frequently distinguishes vague time statements from countable, documented totals.
For a 2026 office/outpatient E/M code (99202-99215), which two methods select the level?
An established patient visit documents a detailed history and exam, low-complexity MDM, and no time statement. What level is supported?
How many of the three MDM elements (problems, data, risk) must be met to support a given office E/M level?