Evaluating Billing Code Distributions in the Emergency Department Following the Implementation of the New Documentation Guidelines.

Objectives: Changes to the Current Procedural Terminology (CPT) evaluation and management (E/M) documentation guidelines implemented on January 1, 2023, were primarily meant to address dissatisfaction with the prior system; however, it was not known how the changes might alter billing distributions. In this study, we compare the proportion of visits for each E/M code before and after the enactment of the changes across 5 emergency departments (EDs) to determine the effects on billing. Methods: This was a retrospective, observational analysis of all ED visits for patients over 18 years across 5 EDs from January 1 to March 31 in the years 2021, 2022, and 2023. In the primary analysis, we compared the distribution of visits for each of the studied CPT E/M codes in the 3 months before and after the enactment of the changes, utilizing a multivariate mixed-effect Poisson regression model. In our secondary analysis, we aimed to determine if the results differed when looking at academic and community sites separately. Results: Across all hospitals, visits coded as level 4 and level 5 comprised a significantly higher proportion of all visits in the postimplementation period (relative risk = 1.40 for level 4 and relative risk = 1.17 for level 5). The proportion of visits coded as levels 1, 2, and 3 significantly decreased in the postimplementation period, while those coded as critical care did not change. The same general trends were found in both academic and community settings separately, although with less statistical significance, particularly at the academic sites. Conclusion: In this observational analysis, we found that overall CPT E/M levels increased after the implementation of the new documentation guidelines, relieving apprehension that the documentation changes may lead to a decrease in reimbursement.