Evaluation and Management (E&M) services comprise a significant payment integrity challenge, costing individual payers millions or even tens of millions of dollars in inappropriate claim spend per year, depending on their size. And the problem appears to be getting worse over time. Cotiviti’s analysis of paid claims over the past five years shows a particularly concerning trend when it comes to emergency room (ER) claims for both physician and facility components. As demonstrated in Figure 1, Level 4 and 5 facility ER E&M claims rose by more than 32% from 2016 to 2021 according to Cotiviti’s analysis while Level 1, 2, and 3 claims decreased by 23%.