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Policy / Article-005

E/M Emergency Department Services Educational Guide

Audience

This resource sheet applies to professionals involved in emergency department E/M services.

References
  • CPT 2026 Professional Edition, AMA
  • AMA CPT Assistant, ED guidance
  • CMS Evaluation & Management Services Guide
  • Official ICD-10-CM / CPT coding rules

Clinical Providers

Physicians

Nurse Practitioners (NPs)

PAs working in ED

Coding & Billing Professionals

Medical Coders

Clinical Documentation Improvement (CDI) specialists

Compliance and audit personnel

Overview

Evaluation and management services are provided in an Emergency department setting for patients requiring urgent or emergent evaluation, typically for acute illness or injury.

Key Points
  • ED services are time and MDM-based.
  • CPT codes for ED services reflect the severity of the patient’s condition and the complexity of care.
  • Documentation must support medical necessity, MDM, and the level of service.
CDI & Audit Considerations

1. Always document acuity and complexity of the ED patient

2. Include data reviewed (labs, imaging, outside records, consults)

3. Specify risk to the patient to support code selection

4. Document interventions and disposition

5. Ensure clarity by avoiding vague statements like “patient evaluated” without detail

Common Audit Triggers

  1. Missing chief complaint or history
  2. Vague exam documentation
  3. Ambiguous MDM justification
  4. Incomplete documentation of interventions or disposition
Documentation Essentials

For each ED encounter, documentation should include:

Chief Complaint / Reason for Visit – concise and specific

History of Present Illness (HPI) – describe onset, severity, progression

Past Medical History / Medications / Allergies – relevant to the acute problem

Physical Examination – problem-focused or extended based on patient acuity

Medical Decision Making (MDM)

  • Number & complexity of problems
  • Data reviewed, ordered, interpreted
  • Risk of morbidity or complications

Assessment & Plan / Interventions:

  • Diagnoses, procedures, treatment plan
  • Disposition (admit, discharge, observation)

Time / Counseling Documentation – If total time is used for code selection, document start/end times, activities, counseling, care coordination

Example Correct Time-Based Note

Total 45 min:
20 min direct patient care,
15 min reviewing labs & imaging,
10 min counseling patient/family regarding discharge instructions and follow-up care.

CPT 2026 E/M Codes & Typical Time

Pro Tip
CPT 99281–99285 are level-determined by MDM or total time, not by setting alone.

CPT Code

Setting

Typical Time on Date of Service

MDM Level

Notes

99281

ED

15 min

Minimal

Minor problem, low complexity

99282

ED

25 min

Low

Low-moderate complexity, straightforward

99283

ED

35 min

Moderate

Moderate severity, multiple diagnoses, moderate MDM

99284

ED

50 min

High

High severity, high complexity, potentially life-threatening

99285

ED

70 min

High

Critical problem, very high risk, intensive MDM

Emergency Department Medical Decision Making (MDM)

Pro Tip
ED documentation should highlight acuity, risk, and interventions performed. See documentation checklist ➔

Component

Minimal

Low

Moderate

High

Number/Complexity of Problems

1 minor

2 minor / 1 stable chronic

Multiple stable chronic or acute

Life-threatening / severe acute

Amount & Complexity of Data

Minimal

Limited (labs/imaging)

Moderate (labs, imaging, outside records, consults)

Extensive, multiple sources, highrisk interpretation

Risk of Complications / Morbidity

Minimal

Low

Moderate 

High – immediate threat to life or organ function

Revision History

01/01/2026
Correct Coding Integrity

03/23/2026
Revised by Mountain Health CO-OP Policy Committee

Disclaimer
This document is for informational purposes only. It should not replace clinical judgment or provide medical advice. Coverage, benefits, and eligibility are determined by the member’s benefit plan. CPT codes and procedures included are for informational purposes only and do not guarantee reimbursement. © CPT Only – American Medical Association