CPT Code 99213: Complete Documentation Requirements & Compliance Guide

What is CPT Code 99213?

CPT code 99213 is one of the most frequently billed evaluation and management (E/M) codes in outpatient settings. It represents an established patient office visit requiring a medically appropriate history and/or examination with low level of medical decision making (MDM).

Since the 2021 E/M guideline changes, CPT 99213 documentation focuses primarily on medical decision making or total time spent. Understanding these requirements is crucial for proper reimbursement and compliance.

CPT Code 99213 Documentation Requirements

Medical Decision Making (MDM) Method

To bill CPT 99213 based on MDM, you need to meet 2 of 3 elements at the low complexity level:

1. Number and Complexity of Problems Addressed2 or more self-limited or minor problems, OR1 stable chronic illness, OR1 acute, uncomplicated illness or injury
2. 2 or more self-limited or minor problems, OR
3. 1 stable chronic illness, OR
4. 1 acute, uncomplicated illness or injury
5. Amount and/or Complexity of Data ReviewedReview of prior external notes from another provider, ORReview of test results, OROrdering of tests
6. Review of prior external notes from another provider, OR
7. Review of test results, OR
8. Ordering of tests
9. Risk of Complications/Morbidity/MortalityLow risk of morbidity from additional diagnostic testing or treatment
10. Low risk of morbidity from additional diagnostic testing or treatment

Time-Based Method

Alternatively, CPT 99213 can be billed based on total time spent on the date of service:

• 20–29 minutes of total physician/qualified healthcare professional time
• Includes face-to-face and non–face-to-face time on the date of encounter
• Must document start/stop times or total time spent

Common CPT 99213 Documentation Errors

Even experienced providers make documentation mistakes that can trigger denials or audits. Here are the most frequent issues:

1. Insufficient MDM DocumentationFailing to clearly document the complexity of problems addressedNot specifying what data was reviewed or orderedSolution: Use specific language like “reviewed CBC results from 10/15” instead of “labs reviewed”
2. Failing to clearly document the complexity of problems addressed
3. Not specifying what data was reviewed or ordered
4. Solution: Use specific language like “reviewed CBC results from 10/15” instead of “labs reviewed”
5. Copy-Paste ErrorsCarrying forward outdated information from previous visitsContradictory statements within the same noteSolution: Review and update all copied content for accuracy
6. Carrying forward outdated information from previous visits
7. Contradictory statements within the same note
8. Solution: Review and update all copied content for accuracy
9. Time Documentation IssuesMissing start/stop times when billing based on timeNot specifying activities included in total timeSolution: Document “Total time: 25 minutes including exam, counseling, and coordination of care”
10. Missing start/stop times when billing based on time
11. Not specifying activities included in total time
12. Solution: Document “Total time: 25 minutes including exam, counseling, and coordination of care”

CPT 99213 vs Other E/M Codes

CPT 99212 vs 99213

• 99212: Straightforward MDM or 10–19 minutes
• 99213: Low MDM or 20–29 minutes
• Key difference: 99213 requires more complex problem management or additional time

CPT 99213 vs 99214

• 99213: Low MDM or 20–29 minutes
• 99214: Moderate MDM or 30–39 minutes
• Key difference: 99214 requires managing unstable chronic conditions or new problems with uncertain prognosis

Best Practices for CPT 99213 Compliance

1. Document Medical Necessity

Always establish why the visit was necessary:

• Chief complaint clearly stated
• History relevant to presenting problem
• Assessment and plan tied to problems addressed

2. Be Specific About MDM Elements

Avoid vague statements. Instead of “multiple chronic conditions,” document:

• “Stable Type 2 diabetes, last A1C 7.2%”
• “Controlled hypertension on current medications”

3. Support Your Billing Level

Ensure your documentation clearly supports the level billed:

• If billing by MDM, explicitly document 2 of 3 elements at low complexity
• If billing by time, document total time and activities performed

How Technology Improves CPT 99213 Documentation Accuracy

Manual chart reviews often miss subtle documentation errors that can lead to denials or compliance issues. Advanced technology solutions can help by:

• Automatically flagging when MDM documentation doesn't support the billed code
• Identifying copy-paste errors and outdated information
• Ensuring time-based billing includes required elements
• Catching mismatches between CPT codes and documented services

For example, Brellium's AI-powered compliance platform automatically audits 100% of patient visits, instantly flagging documentation issues like CPT code mismatches before claims submission. This proactive approach helps practices maintain compliance while reducing audit risk.

Common CPT 99213 Audit Triggers

Payers often target these red flags during audits:

1. High Volume Billing PatternsBilling 99213 for nearly all established patient visitsLack of variation in E/M code distribution
2. Billing 99213 for nearly all established patient visits
3. Lack of variation in E/M code distribution
4. Documentation TemplatingIdentical documentation across multiple patientsGeneric assessment and plans
5. Identical documentation across multiple patients
6. Generic assessment and plans
7. Time vs MDM InconsistenciesDocumentation supports higher level by one method but not the otherMissing time documentation when complexity appears low
8. Documentation supports higher level by one method but not the other
9. Missing time documentation when complexity appears low

Protecting Your Practice from CPT 99213 Compliance Issues

To minimize audit risk and ensure appropriate reimbursement:

1. Implement Regular Training

• Keep providers updated on current E/M guidelines
• Review common documentation errors quarterly
• Share audit findings for continuous improvement

2. Conduct Internal Audits

• Review a sample of 99213 claims monthly
• Compare documentation to billing guidelines
• Address patterns before external audits find them

3. Leverage Compliance Technology

• Use automated tools to catch errors before submission
• Monitor billing patterns for outliers
• Ensure consistent documentation across providers

Conclusion

CPT code 99213 remains a cornerstone of outpatient billing, but proper documentation is essential for compliance and appropriate reimbursement. By understanding the requirements, avoiding common errors, and implementing strong compliance processes, practices can confidently bill 99213 while minimizing audit risk.

Remember: accurate documentation isn't just about compliance—it’s about ensuring quality patient care and protecting your practice’s financial health.

Additional Resources

• AMA CPT E/M Guidelines — Official E/M coding guidelines
• CMS Evaluation and Management Services Guide — Medicare documentation requirements
• AAFP E/M Coding Resources — Family practice coding guidance