E-M Frequency Data for Family Medicine and Internal Medicine

CMS releases annual E/M frequency data based on physician specialty self-selection during Medicare enrollment. Although family medicine includes children, this data reflects Medicare patients, those disabled at any age, and adults 65 and older. Since family and internal medicine both provide primary care, their data are combined here for comparison. 

Office Visit Service Frequencies: New and Established Patients

This section breaks down, based on the latest Medicare data, how Family Medicine and Internal Medicine physicians typically bill common Evaluation and Management (E/M) codes for new and established office visits.

New Patient Office Visits

New patient visits are categorized by the complexity of care provided. Both specialties strongly prefer moderate to high-complexity visits, reflecting the detailed evaluation required during an initial consultation.

Below is the breakdown of how Family Medicine and Internal Medicine physicians bill common E/M codes for new and established office visits.

• 99202 (New Patient, Low Complexity): About 3.6% of new patient visits in Family Medicine are billed as 99202, compared to 2.3% in Internal Medicine. This code reflects visits with a straightforward level of complexity.
   
• 99203 (New Patient, Moderate Complexity): Family Medicine physicians use this code more often, accounting for roughly 39.4% of new patient visits, while Internal Medicine bills it for about 22%. It indicates a moderate level of evaluation and management.
   
• 99204 (New Patient, High Complexity): High complexity visits coded as 99204 make up approximately 51% of new visits in Family Medicine and 58% in Internal Medicine, showing that both specialties frequently see complex cases among new patients.
   
• 99205 (New Patient, Highest Complexity): The highest level of new patient visit, 99205, is billed less often but is notable at 6% in Family Medicine and 17.6% in Internal Medicine, reflecting very complex and detailed evaluations.
   
• 99211 (Established Patient, Minimal Service): Minimal service visits are rare, with Family Medicine billing 1.4% and Internal Medicine 1.3% of established patient visits under this code.
   
• 99212 (Established Patient, Low Complexity): This low complexity code is also infrequent, with 1.8% usage in Family Medicine and 2.1% in Internal Medicine.
   
• 99213 (Established Patient, Moderate Complexity): Moderate complexity visits are common for established patients, representing 32.1% of Family Medicine and 29.8% of Internal Medicine visits.
   
• 99214 (Established Patient, High Complexity): The majority of established visits fall here, with Family Medicine billing 60.3% and Internal Medicine 59.9% under this code.
   
• 99215 (Established Patient, Highest Complexity): The highest complexity for established patients is less frequent but still significant, billed at 4.5% in Family Medicine and 6.9% in Internal Medicine.

Initial Inpatient Services (Codes 99221–99223)

This section covers how Family Medicine and Internal Medicine physicians bill for initial hospital inpatient visits at different complexity levels.

• 99221 (Initial Inpatient, Low Complexity): At this lowest level, Family Medicine physicians bill 3.2% of initial inpatient visits, while Internal Medicine physicians bill slightly less, at 2.1%.
   
• 99222 (Initial Inpatient, Moderate Complexity): The moderate complexity code 99222 is billed for about 33.9% of initial inpatient visits by Family Medicine and 27.4% by Internal Medicine physicians.
   
• 99223 (Initial Inpatient, High Complexity): The highest-complexity initial inpatient service, code 99223, is billed more frequently by Internal Medicine physicians, accounting for 70.6% of visits compared to 63% for Family Medicine.
   

Internists bill nearly 10% more initial hospital services at the highest complexity level than family physicians. However, family physicians still bill most (63%) of their initial hospital visits at this highest complexity level.

Subsequent Hospital Services (Codes 99231–99233)

This section outlines the billing patterns for follow-up inpatient visits by Family Medicine and Internal Medicine physicians.

• 99231 (Subsequent Inpatient, Low Complexity): Family Medicine physicians bill 6.3% of subsequent inpatient visits at this lowest level, while Internal Medicine physicians bill 4.1%.
   
• 99232 (Subsequent Inpatient, Moderate Complexity): The moderate complexity code 99232 is the most commonly billed for subsequent visits, with Family Medicine at 59.3% and Internal Medicine at 55.6%.
   
• 99233 (Subsequent Inpatient, High Complexity): High complexity subsequent visits coded as 99233 account for 34.4% of Family Medicine and 40.3% of Internal Medicine inpatient visits.
   

Over the years, both specialties have slightly increased their use of the middle-level code (99232), significantly decreased the use of the lowest-level code (99231), and increased billing at the highest level (99233). Since 99233 has a higher error rate in CMS’s Comprehensive Error Rate Testing (CERT) report, it is essential for physicians who frequently use this code to review and ensure documentation meets all requirements carefully.

Observation and Admission/Discharge on the Same Day (Codes 99218–99220, 99234–99236)

This section reviews billing frequencies for observation admissions and services involving admission and discharge by Family Medicine and Internal Medicine physicians on the same day.

• Observation Admissions (Codes 99218–99220): Both Family Medicine and Internal Medicine physicians report 0% billing for observation admission codes 99218, 99219, and 99220, indicating these codes are rarely or not used in this dataset.
   
• Admission and Discharge on the Same Day (Code 99234): Family Medicine physicians bill 9.5% of these services at the lowest level, closely matched by Internal Medicine at 9.1%.
   
• Admission and Discharge on the Same Day (Code 99235): Family Medicine bills 46.2% at the mid-level, while Internal Medicine bills 34.9%.
   
• Admission and Discharge on the Same Day (Code 99236): Internal Medicine physicians bill 56.1% for the highest complexity code, noticeably higher than Family Medicine at 44.4%.
   

The usage of observation codes 99218–99220 parallels patterns seen in initial inpatient services, with internists billing the highest-level codes more often. Family physicians tend to bill more mid-level services for same-day admission and discharge, while internists more frequently bill the highest level.

It’s important to remember that CMS frequency data reflects overall trends and is not intended as prescriptive guidance. Variations in practice style and documentation quality exist. Reviewing this comparative data can be useful for identifying areas for audit or physician education.

Disclaimer

This frequency data represents Medicare billing patterns and should not be interpreted as specific recommendations. Individual physician practices and patient populations vary. Always ensure coding decisions comply with current official guidelines and documentation standards.

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