CPT Code 99201: Deleted E&M Code Guide

• CPT Codes
• 99201

CPT Code 99201: Deleted E&M Code Guide

CPT code 99201 was deleted by CMS in 2021. Learn why this E&M code was removed and which new patient evaluation codes behavioral health providers should use.

Quick Reference

Code

99201

Code System

CPT

Category

CPT Codes

Published

Mar 4, 2026

Reading Time

6 min

CPT® is a registered trademark of the American Medical Association. All CPT code descriptions on this page are paraphrased in original wording; consult the current CPT® codebook published by the AMA for authoritative descriptors.

Understanding CPT Code 99201: A Deleted E&M Code

CPT code 99201 was historically used for new patient office or outpatient visits with the simplest level of medical decision making. However, as of January 1, 2021, CMS permanently deleted this code as part of a major restructuring of the Evaluation and Management (E&M) code set. If you are searching for 99201, this guide explains why it was removed and which codes you should use instead.

What Was CPT Code 99201?

Before its deletion, CPT code 99201 described a new patient office or outpatient visit that required three key components:

The typical face-to-face time was approximately 10 minutes. It was the lowest-level E&M code available for new patient encounters and was commonly used in behavioral health settings for brief intake screenings, simple follow-up consultations with new patients, or initial assessments where the clinical complexity was minimal.

In behavioral health specifically, 99201 was sometimes used for new patients presenting with a single, uncomplicated concern such as a medication check referral or a brief consultation about treatment options. However, even before its deletion, many payers had already begun discouraging its use due to very low reimbursement rates.

• A problem-focused history
• A problem-focused examination
• Straightforward medical decision making

Why CMS Deleted 99201

The 2021 E&M restructuring was one of the most significant changes to office visit coding in decades. CMS and the AMA made several fundamental shifts that rendered 99201 unnecessary.

Elimination of history and exam requirements. Under the old system, the level of E&M code was determined by the complexity of the history, examination, and medical decision making. The 2021 guidelines eliminated history and exam as required elements for code selection. Instead, providers now select E&M level based on either medical decision making complexity or total time spent on the encounter.

Alignment of new and established patient codes. With the restructuring, CMS determined that the lowest level of medical decision making (straightforward) should begin at the 99202 level for new patients. Since the distinction between 99201 and 99202 under the old framework relied heavily on history and exam elements that were being eliminated, there was no longer a meaningful clinical distinction to support a separate lower-level code.

Simplification of the code set. The deletion of 99201 was part of a broader effort to simplify E&M coding, reduce administrative burden, and make documentation requirements more clinically relevant.

What Codes to Use Instead

If you previously billed 99201 for new patient encounters, you should now evaluate which of the remaining new patient E&M codes is appropriate.

New Patient Office Visit Codes (Current)

• 99202 — Straightforward medical decision making, 15-29 minutes. This is now the lowest-level new patient E&M code and the most direct replacement for encounters that previously qualified as 99201.
• 99203 — Low complexity medical decision making, 30-44 minutes. Appropriate when the encounter involves more data review, a greater number of diagnoses, or moderate risk.
• 99204 — Moderate complexity medical decision making, 45-59 minutes. Common for initial psychiatric evaluations or intake assessments involving multiple conditions.
• 99205 — High complexity medical decision making, 60-74 minutes. Used for complex new patient encounters with significant comorbidities or high-risk presentations.

Choosing the Right Replacement Code

When transitioning from 99201 to current codes, consider these factors:

• Medical decision making complexity. Evaluate the number and complexity of problems addressed, the amount and complexity of data reviewed, and the risk of complications or morbidity.
• Total time. If time-based billing is more favorable, document total time spent on the date of the encounter, including both face-to-face and non-face-to-face activities such as review of records, care coordination, and documentation.
• Documentation focus. Under the current guidelines, your documentation should support the level of medical decision making rather than the extent of history and exam performed.

Impact on Behavioral Health Providers

The deletion of 99201 had specific implications for behavioral health treatment centers and practices.

Intake and screening encounters. Brief new patient screenings that previously qualified as 99201 will often meet criteria for 99202 under the current framework, particularly when medical decision making includes reviewing external records, assessing risk factors, or coordinating with other providers.

Reimbursement considerations. Since 99202 reimburses at a higher rate than the former 99201, many behavioral health providers actually saw a net positive financial impact from this change, assuming they documented appropriately to support the 99202 level.

Training and workflow updates. Providers and billing staff who were accustomed to using 99201 needed to update their coding practices. If your organization has not yet updated internal coding templates or superbills, remove 99201 immediately to prevent claim denials.

Common Mistakes to Avoid

Even years after the deletion of 99201, some organizations continue to make errors related to this code change.

• Submitting claims with 99201. All payers will deny claims with this code. Ensure your EHR and billing systems have removed 99201 from all code picklists and templates.
• Downcoding to 99211. Some providers mistakenly use 99211 (established patient, may not require physician presence) as a replacement for 99201. These codes serve different purposes. 99211 is for established patients only and does not require physician-level medical decision making.
• Underdocumenting 99202 encounters. Because 99202 requires straightforward medical decision making, providers must document at least two of the three MDM elements (number and complexity of problems, data reviewed, risk) at the straightforward level.
• Ignoring time-based billing. For encounters where the provider spends significant time on non-face-to-face activities, time-based billing may support a higher E&M level than MDM alone.

Documentation Requirements for Replacement Codes

Since 99201 is no longer valid, here are the documentation requirements for 99202, the most common replacement.

For 99202 based on medical decision making, document:

For 99202 based on time, document:

• The nature and number of problems addressed during the encounter
• Any data reviewed or ordered, including records, tests, or consultations
• The risk associated with the presenting problem and management options
• A clear assessment and plan

• Total time spent on the date of the encounter (15-29 minutes)
• Activities performed during that time, such as reviewing records, counseling, care coordination, and documentation
• That time is being used as the controlling factor for code selection

Compliance Considerations

Organizations should take the following steps to ensure compliance in the post-99201 landscape:

• Audit historical claims. If your organization continued to bill 99201 after January 1, 2021, identify and address any denied or improperly paid claims.
• Update coding resources. Remove 99201 from all internal references, coding sheets, and training materials.
• Train all billing staff. Ensure coders and billers understand the current E&M framework and can correctly assign 99202-99205 based on MDM or time.
• Review EHR templates. Confirm that your electronic health record system reflects the current E&M structure and does not auto-populate 99201.

Related Billing Codes

• 96164
• 96165
• 96372
• 99202
• 99203
• 99204

Common questions

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