Last Updated: January 2026 | Verified for 2026 AMA, CPT & CMS Guidelines
Under the 2023–2026 E/M guidelines, code selection is driven by Medical Decision Making (MDM) OR Total Time. You do not need to document history or physical exam to qualify for the level, although a clinically appropriate exam is expected.
To bill 99232 by MDM, you must meet 2 of the 3 elements for Moderate complexity. This is the most common method for hospitalists and consultants:
Element 1: Number & Complexity of Problems 1 acute illness with systemic symptoms (e.g., Pneumonia, Pyelonephritis).
2 or more stable chronic illnesses (e.g., stable CHF + controlled Diabetes).
1 chronic illness with mild exacerbation (e.g., COPD flare responding to meds).
1 undiagnosed new problem with uncertain prognosis (e.g., new lump, new shortness of breath).
Element 2: Amount & Complexity of Data (Must meet 1 of 3 categories) Category 1: Review of prior external notes AND review of results of 2 unique tests (e.g., Labs + Echo).
Category 2: Independent interpretation of a test performed by another (e.g., you look at the CT scan images yourself, not just the report).
Category 3: Discussion of management with an external physician (e.g., consulting Infectious Disease).
Element 3: Risk of Complications/Morbidity (Moderate Risk) Prescription Drug Management: This is the most common trigger. Deciding to start, stop, or adjust a medication counts. Deciding not to change a med after review also counts.
Decision regarding minor surgery with patient risk factors.
Diagnosis or treatment significantly limited by Social Determinants of Health (SDOH) (e.g., homelessness affecting discharge planning).
If coding by time, you must document at least 35 minutes of total time on the date of the encounter.
What Counts:
Reviewing the chart before seeing the patient.
Bedside exam and counseling.
Ordering medications, labs, or tests.
Documenting the note in the EHR.
Speaking with family (if the patient is unable to communicate or for care coordination).
Care coordination with other providers (consultants, case managers). What Does NOT Count:
Time spent by clinical staff (nurses).
Time spent on days other than the visit date (e.g., reviewing labs the next morning) .
To withstand an audit, vague phrases like “stable” or “continue meds” are insufficient. Your note must explicitly support the “Moderate” nature of the visit:
While 99232 is diagnosis-agnostic, these conditions frequently justify moderate complexity due to the nature of the illness or the risk of treatment:
The “One Visit Per Day” Rule: Medicare pays for only one E/M per patient per day by physicians of the same specialty in the same group.
Scenario: Dr. A (Hospitalist) rounds in the AM. Dr. B (Partner Hospitalist) is called back in the PM for fever.
Action: Combine the work of both visits into ONE note and bill ONE code (e.g., 99233 if combined complexity rises) .
Different specialists (e.g., Hospitalist and Cardiologist) can both bill 99232 on the same day if treating distinct conditions. Documentation must clearly delineate the separate roles (e.g., “Cardiology managing acute arrhythmia” vs “Hospitalist managing pneumonia”) .
You cannot bill 99232 and 99238/99239 (Discharge Management) on the same day. The discharge code covers all E/M services provided by the attending on that date .
Used by a surgeon (or same specialty partner) during a global surgical period (10 or 90 days) if the visit is for a completely unrelated medical problem.
Example: An Orthopedic surgeon manages a patient for new onset chest pain 2 days after hip surgery (unrelated to the hip).
Note: Routine post-op pain control or wound checks are bundled and not billable .
Use if a distinct procedure was performed on the same day as the visit.
Example: You evaluate a patient for worsening respiratory failure (99232) and then decide to insert a central line (36556) later that day. Append -25 to 99232.
Required for teaching physicians involving residents in the care. It certifies that the teaching physician was present for the critical portion of the service .
| Code | MDM Level | Time (Min) | Typical Clinical Scenario |
|---|---|---|---|
| 99231 | Low / Straightforward | 25 | Stable, recovering patient. “Patient feels better. Vitals stable. Continue current meds.” No new problems. |
| 99232 | Moderate | 35 | Responding but complex. Patient recovering from pneumonia but still requires O2 and IV antibiotics. Managing diabetes sliding scale. Rx changes made. |
| 99233 | High | 50 | Unstable or Escalating. Patient deteriorating. New sepsis. Transfer to ICU considered. Decision to start pressors or consult multiple specialists. |
Patient: Day 3 admission for Pneumonia. Still febrile. O2 increased from 2L to 4L.
Data: Physician reviews CXR (worsening infiltrates) and culture results (resistant organism).
Risk/Plan: Decision to switch antibiotics to Linezolid (Prescription Drug Management). Consult Infectious Disease.
Coding: 99232.
Rationale: 1 Acute illness with systemic symptoms (Pneumonia) + Prescription drug management (Abx change) = Moderate MDM .
Patient: Day 2 post-op bowel resection. Oliguria and rising creatinine (AKI).
Action: Nephrologist is consulted. Reviews urine lytes, orders fluid bolus, holds NSAIDs.
Coding: 99232.
Rationale: New problem with uncertain prognosis (AKI) + Prescription drug management (Holding NSAIDs is a management decision).
Note: Nephrologist bills this; Surgeon cannot bill for this day unless using Modifier 24 for a truly unrelated issue.
Patient: Stable CHF patient ready for discharge but lacks housing.
Action: Physician spends 35 minutes coordinating with social work and family to arrange shelter placement.
Coding: 99232 (Based on Time).
Rationale: Even if MDM is low (stable CHF), the total time (35 mins) justifies 99232. SDOH limiting discharge is also a “Moderate Risk” factor .
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