May 17, 2023

Changes were made for 2023 to the E/M services provided in the Emergency Department (ED). The changes to the subsection were made to align with the 2021 changes to the outpatient E/M codes.

The first change is to 99281 which was revised to decrease the level of service similar to the 99211 (Office or outpatient visit). The descriptor was revised to specifically say, “May not require the presence of a physician or other qualified health care professional.”

Time is not used to determine the E/M level of the ED Service. Medical decision making (MDM) is used to determine the level with no distinction between new and established patients.

  • 99281 – No MDM (This level may or may not require presence of medical provider/can be clinical staff only visit.)
  • 99282 – Straightforward MDM
  • 99283 – Low MDM
  • 99284 – Moderate MDM
  • 99285 – High MDM

Considerations for reporting ED Services for 2023:

  • There is no distinction between new and established patients in the ED.
  • Time is not used in leveling, only MDM is used.
  • Critical Care codes and ED E/M codes may be reported on the same day. New guidelines clarify that these two codes can be used together, as previously it was stated that critical care codes could be used with another E/M but did not specify ED services.
  • Consultations provided in the ED are reported using the office/outpatient consultation codes 99241-99245. Please see consultation guidelines for specific requirements.
  • Procedures provided in the ED may be separately reported in addition to the E/M CPT code. Use the appropriate modifier(s) to report the separately identifiable E/M service.
  • Physician convenience may affect appropriate reporting. For example, a patient seen in the ED for the convenience of the physician/QHP, the office or outpatient service (99202-99215) would be reported, not an ED E/M (99282-99285).



Anne Mettler-Huebner, MT(ASCP), CCS, CCS-P, CPC, CPC-I

Auditor | Excite Health Partners



AMA CPT 2023 Professional Edition

AMA CPT E/M Companion 2023