What the 2026 E/M Guideline Updates Mean for Specialty Practices

Evaluation and management coding has been in a state of continuous refinement since the 2021 overhaul, and 2026 is no exception. The medical decision making table remains the backbone of code selection, but payers are increasingly scrutinizing how practices document the data reviewed and risk elements.

For specialty practices, the most consequential change is the clarification around independent interpretation of tests. If your providers routinely review imaging or diagnostic studies performed elsewhere, the documentation must explicitly state the interpretation — a note that simply mentions the result no longer qualifies.

We’re also seeing payers tighten review on time-based billing. When total time is used for code selection, auditors now expect the note to describe what activities the time was spent on, not just a total minute count.

Our recommendation: audit a sample of your highest-volume E/M codes against the current MDM table quarterly. Practices that do this consistently catch drift early — both undercoding that costs revenue and overcoding that creates compliance exposure.