Latest Medical Coding News & Trends | Nym Health Blog

E/M Coding Guidelines for 2026: Quick-Reference Cheat Sheet

Written by Kacie Geretz, Director of Growth Enablement | Sep 11, 2025, 6:18:53 PM

Evaluation and management (E/M) code selection rules have been stable since 2021, but the billing rules around them change every year. This cheat sheet puts the 2026 E/M coding guidelines in one place, from office and emergency department (ED) visit levels to Medicare telehealth billing, G2211, and what changes in 2027.

Payers are looking harder at E/M levels, and the guidelines still leave room for interpretation. Your providers need to document consistently and follow the same leveling philosophy, so your E/M distribution holds up when a payer compares it to peers. If a level is challenged, you want to show it was chosen the same way every time.

Overview of E/M Coding Guidelines for 2026

Medical decision making (MDM) and total time replaced history and exam as the basis for office visit levels in January 2021, and Current Procedural Terminology (CPT) extended a similar framework to hospital, ED, nursing facility, and home visits in January 2023 (1).

Physicians and other qualified health care professionals (QHPs) select an office visit level using one of two methods:

  • Medical decision making: Based on the number and complexity of problems addressed, the data reviewed and analyzed, and the risk of patient management. Two of the three elements must meet or exceed the level.
  • Total time: All time the physician or QHP personally spends on the date of the encounter, including record review, documentation, and care coordination, not just face-to-face time.

You still document a medically appropriate history and exam, but they no longer drive the level. Use whichever method better reflects the work performed, and make sure the documentation clearly supports the one you used.

Quick-Reference E/M Cheat Sheet

Office Visit Levels by MDM and Time

Code

Patient Type

MDM Level

Minimum Time

99202

New

Straightforward

15 min

99203

New

Low

30 min

99204

New

Moderate

45 min

99205

New

High

60 min

99211

Established

N/A*

N/A*

99212

Established

Straightforward

10 min

99213

Established

Low

20 min

99214

Established

Moderate

30 min

99215

Established

High

40 min

*99211 doesn't require a physician or QHP to be present and isn't selected by MDM or time.

Prolonged Services

Prolonged services add-ons apply only to 99205 and 99215 selected by time. CPT +99417 is reported per additional 15 minutes starting at 75 minutes for 99205 or 55 minutes for 99215. Medicare doesn't accept 99417 and uses Healthcare Common Procedure Coding System (HCPCS) code G2212 instead, which starts at 89 minutes for 99205 and 69 minutes for 99215 (1).

Emergency Department Visit Levels

ED E/M codes 99281-99285 use the same MDM framework, with one difference: time doesn't count. Levels run from straightforward (99282) to high (99285). Like 99211, 99281 may not require a physician or QHP to be present (2).

Telemedicine Codes 98000-98016

CPT codes 98000-98016 are the codes the AMA created specifically for telemedicine. Medicare largely doesn't pay them, and other payers vary, so check each contract first (3). For Medicare patients, bill the standard office E/M codes (99202-99215) with a telehealth place of service (POS) code and modifier:

  • Audio-video visits: Use POS 02 for telehealth outside the patient's home (paid at the facility rate) or POS 10 for telehealth in the patient's home (paid at the non-facility rate), and append modifier 95 (4). The Centers for Medicare & Medicaid Services (CMS) has proposed new telehealth billing modifiers for 2027 (5).
  • Audio-only visits: Add modifier 93, and document that video was available but the patient couldn't use it or didn't consent to it.

Medicare E/M Updates for 2026

2026 Physician Fee Schedule Changes

The 2026 Medicare Physician Fee Schedule (MPFS) final rule didn't change how office levels are selected. It did extend G2211 to home or residence visits and permanently removed telehealth frequency limits for subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations (6).

G2211 Add-On Code

G2211, payable since January 1, 2024, reflects the extra work of an ongoing care relationship, where you're the continuing focal point for a patient's care or you're managing a single serious or complex condition over time (7).

  • Report it with 99202-99215 and, starting in 2026, home or residence visits (99341-99350). There's no frequency limit or specialty restriction.
  • Since 2025, it can be billed the same day as an annual wellness visit (AWV), vaccine administration, or any Medicare Part B preventive service when the base E/M carries modifier 25 (7).
  • Federally qualified health centers (FQHCs) and rural health clinics (RHCs) can't bill it separately, and commercial and Medicaid coverage varies.

G2211 doesn't fit one-time or time-limited visits, so don't add it by default.

Medicare Telehealth Flexibilities Through 2027

The Consolidated Appropriations Act, 2026, extended Medicare telehealth flexibilities through December 31, 2027 (8). Until then, non-behavioral health telehealth has no geographic restrictions, the patient's home counts as an originating site, audio-only visits are allowed, FQHCs and RHCs can serve as distant site providers, and all eligible practitioners can furnish telehealth.

Behavioral and mental health telehealth works differently. Audio-only behavioral health care is now permanent when the patient can't use or doesn't consent to video, and the in-person visit requirement for most mental health telehealth services is delayed until January 1, 2028 (8).

What to Watch for in 2027

The 2027 CPT code set adds 299 codes, deletes 80, and revises 74 (9). For E/M, the biggest change is in maternity care. Starting January 1, 2027, the traditional global maternity codes are deleted and replaced with phase-specific reporting for antepartum, delivery, and postpartum care (10). Antepartum visits are reported individually with E/M codes, so each prenatal visit is leveled by MDM or total time and needs documentation that supports that level (11).

If your team has coded prenatal care under one global code for years, update templates and provider education before January, and plan for more E/M claims.

Four other items to track:

  • Payer downcoding: Several payers have announced automatic E/M downcoding policies in the last year (12). Make sure documentation supports the MDM for each patient, with providers recording everything they did for that patient.
  • Same-day services: Under the 2027 proposed fee schedule, when an office E/M visit is billed on the same day as a 0-, 10-, or 90-day global procedure, the most expensive service would be paid at 100% and every other procedure or E/M visit that day at 50% (13).
  • G2211: CMS has proposed replacing the G2211 add-on code with a modifier on the base E/M code that raises its payment by 16% (13).
  • The final rule: CMS expected to release the 2027 MPFS final rule in early November (10). Check it for the final telehealth modifier, same-day service, and G2211 policies before year-end.

How Technology Helps Apply E/M Coding Guidelines Accurately

Each change above is one more rule your coders have to apply, and a missed update can repeat across hundreds of encounters.

While computer-assisted coding (CAC) tools suggest codes for a coder to review and approve, Nym's autonomous medical coding engine codes the encounter and routes it to billing with no human intervention. While machine learning (ML)-only engines need new data to retrain before they reflect a guideline change, which delays the update, Nym's rules-based approach updates when the guidelines change, so annual AMA and CMS updates take effect without a retraining cycle.

Unlike black box AI solutions, Nym's engine provides a transparent audit trail for every code assignment. That gives you a record of consistent E/M capture across encounters, so when a payer questions a level, your team can point to the documentation and guideline behind it. Encounters with missing or ambiguous documentation go to your coders with the specific issue flagged. At Inova, autonomous medical coding increased average charges per ED encounter by more than 10% through more complete, guideline-consistent capture of bedside procedures and E/M levels.

See how Nym's engine codes your E/M encounters, with an audit trail behind every code.

Talk With Our Team

Sources

  1. American Academy of Family Physicians. Evaluation and Management. Retrieved October 27, 2026, from https://www.aafp.org/practice-operations/billing-and-coding/evaluation-management
  2. American College of Emergency Physicians. 2023 ED E/M Guidelines FAQs. Retrieved November 2, 2026, from https://www.acep.org/administration/reimbursement/reimbursement-faqs/2023-ed-em-guidelines-faqs
  3. American Academy of Family Physicians. Telehealth, Audio, Virtual, and Digital Visits. Retrieved October 27, 2026, from https://www.aafp.org/practice-operations/billing-and-coding/telehealth-audio-virtual-digital-visits
  4. American College of Physicians. Video Visits Billing, Coding and Regulations Information. Retrieved November 4, 2026, from https://www.acponline.org/practice-career/business-resources/telehealth-guidance-and-resources/video-visits-billing-coding-and-regulations-information
  5. American Health Care Association and National Center for Assisted Living. (15 July 2026). CMS Issues CY 2027 Medicare Physician Fee Schedule. Retrieved November 2, 2026, from https://www.ahcancal.org/News-and-Communications/Blog/Pages/CMS-Issues-CY-2027-Medicare-Physician-Fee-Schedule.aspx
  6. Centers for Medicare & Medicaid Services. (9 December 2025). Medicare Physician Fee Schedule Final Rule Summary: CY 2026. Retrieved November 2, 2026, from https://www.cms.gov/files/document/mm14315-medicare-physician-fee-schedule-final-rule-summary-cy-2026.pdf
  7. American Academy of Family Physicians. G2211: What It Is and How to Use It. Retrieved October 27, 2026, from https://www.aafp.org/practice-operations/billing-and-coding/evaluation-management/g2211-what-it-is-and-how-to-use-it
  8. Littrell, A. (10 February 2026). What changed in Medicare telehealth under the 2026 spending bill. Medical Economics. Retrieved November 2, 2026, from https://www.medicaleconomics.com/view/what-changed-in-medicare-telehealth-under-the-2026-spending-bill
  9. American Medical Association. (9 September 2026). AMA releases CPT 2027 code set. Retrieved November 2, 2026, from https://www.ama-assn.org/press-center/ama-press-releases/ama-releases-cpt-2027-code-set
  10. American Medical Association. (17 September 2026). FAQs: Preparing for CPT 2027 maternity care services code changes. Retrieved November 2, 2026, from https://www.ama-assn.org/practice-management/cpt/faqs-preparing-cpt-2027-maternity-care-services-code-changes
  11. American Medical Association. (17 September 2026). FAQs: CPT 2027 coding for antepartum care (prenatal). Retrieved November 2, 2026, from https://www.ama-assn.org/practice-management/cpt/faqs-cpt-2027-coding-antepartum-care-prenatal
  12. Kelley, C., & Hardy, J. (4 September 2026). Are payors downcoding your evaluation and management services? Why every practice should be paying attention. Medical Economics. Retrieved November 2, 2026, from https://www.medicaleconomics.com/view/are-payors-downcoding-your-evaluation-and-management-services-why-every-practice-should-be-paying-attention
  13. Centers for Medicare & Medicaid Services. (14 July 2026). Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule. Retrieved November 4, 2026, from https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-proposed-rule