Commentary|Articles|April 29, 2026

How the federal government changed E&M coding

Fact checked by: Austin Littrell, Kirsty Mackay

How the widespread adoption of electronic medical records quietly transformed the way primary care physicians code office visits, and their bottom lines.

The federal government began pushing the adoption of electronic medical records (EMRs) in 2004. With the Health Information Technology for Economic and Clinical Health Act of 2009, practices received financial incentives for the meaningful use of EMRs. These incentives became penalties in 2015 when the government began financially punishing practices that did not use certified EMRs. Perhaps one in 10 physicians used an EMR in 2000 (with the vast majority being employed by hospital systems), whereas today EMR adoption is close to 100%.

An unintended — and I would surmise, unanticipated — consequence of these actions has been a shift toward the use of higher evaluation and management (E&M) codes. In this article, I will look at office follow-up codes 99211-99215 and a significant change in E&M coding.

EMRs improve — and increase — documentation. Yes, they can be a pain, but generally speaking, they align your documentation with the current procedural terminology (CPT) guidelines that determine your coding level. This alignment has improved your bottom line.

In the pre-EMR year 2000, physicians used the two lowest E&M codes, 99211 and 99212, 20% of the time*. These codes have very low care and documentation bars. In contrast, 99214 and 99215 required much more documentation and were used just 23.9% of the time. The more complex the care, the more complex the documentation, so physicians used lower codes rather than spend nights and weekends justifying the use of higher codes through documentation.

As EMR use increased, documentation increased. As documentation increased, so did physician coding. No surprise there.

By 2008, 9% of private practice physicians and 17% of hospital-owned physicians were using EMRs. The shift toward higher E&M codes had begun. The use of 99211 and 99212 had declined from 20% to 14%, while that of 99214 and 99215 had increased from 23.9% to 37.2%.

Today? Primary care physicians are using 99211 and 99212 less than 3% of the time. I cannot recall the last time I saw a 99211.

Primary care physicians used 99214 and 99215 67.2% of the time in 2024, nearly three times as often as they used them a quarter century ago. The following chart demonstrates this coding evolution.

As much as many of us have griped about EMRs, a shift of this magnitude would not have happened without them.

EMRs are expensive. Are they a good investment? Let’s look at reimbursement, using the 2026 National Medicare Physician Fee Schedule:

CODE

REIMBURSEMENT

99211

$24.38

99212

$59.45

99213

$95.19

99214

$135.61

99215

$192.39

A 99214 reimburses at 2.2 times as much as a 99212, and a 99215 pays 3.2 times more than a 99212. In first incentivizing physicians to adopt EMRs and then penalizing those who didn’t, the federal government transformed E&M coding.

I could make a solid argument that physicians undercoded during the “paper chart” era, primarily because the documentation requirements were too high a hurdle. It often took 30 to 45 minutes to document a complex visit.

Today, thanks to EMRs, documentation is easier, and physicians are being paid more fairly for the work they have been doing for decades.

It’s a good thing.

*The author used Medicare E&M data in this article. He has compared physician E&M coding for Medicare and non-Medicare patients several times during his career and found no substantive differences in coding.

Lucien W. Roberts, III, M.H.A., FACMPE, is a mostly retired practice administrator and long-time Physicians Practice contributor.