Think Like an Auditor

E/M Audit Checklist

A focused review tool for medical decision-making, time, risk, data, documentation, and level-of-service validation.

Use this original checklist to support a consistent, defensible review of evaluation and management services.

Audit purpose: Verify that the reported E/M category and level are supported by the medical record, current coding guidance, medical necessity, and applicable payer requirements.

Encounter & Code Family Verification

  • Correct patient, date of service, provider, and place of service are identified.
  • The selected E/M code family matches the documented setting and encounter type.
  • New versus established patient status is verified when applicable.
  • Initial, subsequent, discharge, consultation, emergency, nursing facility, home, or other category requirements are reviewed as applicable.
  • The reported service is eligible for selection by medical decision-making, total time, or another category-specific method.

Medical Decision-Making Overview

  • The record clearly identifies the problems evaluated or managed during the encounter.
  • The amount and complexity of data reviewed and analyzed are supported.
  • The risk of patient management is documented and clinically relevant.
  • The reported MDM level is based on the required number of MDM elements.
  • No element is credited solely because information appears elsewhere in the record without evidence that it affected the encounter.

Problems Addressed

  • Each condition credited toward MDM was evaluated or treated during the encounter.
  • The documented status of each problem supports its assigned complexity.
  • Stable, worsening, uncontrolled, acute, chronic, and threat-related descriptions are clinically supported.
  • Conditions merely listed in the history or problem list are not counted unless addressed.
  • The assessment and plan show how each credited problem affected management.

Data Reviewed & Analyzed

  • Tests, documents, records, and historian information credited toward data are identified.
  • Orders and reviews are not counted twice when the applicable rules treat them as a single data element.
  • Independent interpretation is separately documented and is not already included in another reported service.
  • Discussion with an external physician or qualified health care professional is documented when credited.
  • The data level is calculated using current category-specific E/M requirements.

Risk of Patient Management

  • Management decisions are clearly documented.
  • Prescription drug management, procedures, hospitalization decisions, or other risk factors are supported by the record.
  • Risk is based on the management of the patient, not solely on the seriousness of a diagnosis.
  • Social factors affecting management are documented when relevant.
  • The documented risk supports the level selected under current E/M guidance.

Time-Based Code Selection

  • The selected E/M category permits code selection by time.
  • Total qualifying time is documented for the correct date or service period.
  • The documented time meets the current threshold for the reported code.
  • Only qualifying physician or other qualified health care professional activities are included.
  • Separately reported procedures and nonqualifying activities are excluded.
  • Shared or split service time is evaluated under current payer and organizational requirements when applicable.

Level-of-Service Validation

  • The reported level is supported by MDM, time, or the applicable category-specific requirements.
  • History and examination are medically appropriate and support the clinical record, even when they do not determine the level.
  • The service is not upcoded based on volume of documentation, template length, or copied text.
  • The final code selection is consistent with the documented work and medical necessity.
  • Applicable payer, facility, and organizational policies have been considered.

Modifiers & Separately Reported Services

  • Modifier 25 is supported by a significant, separately identifiable E/M service when reported with a procedure.
  • Modifier 24 is supported by an unrelated E/M service during a postoperative period when applicable.
  • Modifier 57 is supported by the decision for major surgery when applicable.
  • A separate E/M service is not reported for work integral to another procedure or service.
  • Documentation supports all other modifiers and distinct-service reporting.

Documentation Integrity

  • The note is authenticated by the responsible professional.
  • The assessment and plan are clear, complete, and internally consistent.
  • Copied or carried-forward information is clinically relevant and does not inflate the level.
  • Contradictory documentation is resolved before final audit determination.
  • Amendments, addenda, and late entries comply with organizational policy.

Final Audit Determination

  • The audited E/M code is supported as reported.
  • A lower or higher level is supported by the documentation.
  • A different E/M category or code family is appropriate.
  • A modifier correction is required.
  • Additional documentation clarification or provider education is recommended.
  • The finding, rationale, guideline source, and corrective action are documented.

Audit Finding Classification

☐ Supported as reported
☐ Level correction required
☐ Code family correction required
☐ Modifier correction required
☐ Documentation deficiency
☐ Education opportunity

Auditor reminder: Credit only the work that is documented, applicable to the encounter, and permitted under the current E/M category rules.

Educational Disclaimer

This original educational resource does not reproduce proprietary CPT® tables or code descriptors. Use it with the current CPT® code set and E/M guidance, ICD-10-CM Official Guidelines, CMS instructions, payer policies, contractual requirements, and organizational standards. CPT® is a registered trademark of the American Medical Association.