# billing based on time



## Colliemom (Aug 7, 2008)

When billing based on time, is it still necessary to document the HPI, exam and MDM?  If you document the time, with a brief description of what was discussed with the patient in the counseling, does this meet the guidelines for billing that level?

We have a physician who takes a VERY long time to complete his notes.  Since we do not bill for a visit until the note has been completed we are running into a timely filing issue.  If we could simplify things for him, we might be able to get his billing submitted on time.  One possible solution was to have him document a chief complaint and a brief description of what was done.  For example "I spent 40 mintues with the patient, and more than 50% of the visit was spent in counseling the patient about the progression of her disease and possible treatment options."  In your opinion, would this be enough documentation to bill a 99215?  (if there is no documentation of an HPI, exam or MDM)


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## FTessaBartels (Aug 7, 2008)

*The MD should get notes done sooner*

I'm having trouble imagining why it is taking the MD so long to do his notes that the denials are for timely filing; and you're right, Kattkia, in seeing that this needs to be addressed and corrected. 

BUT what should happen is that an analysis of the effects of his delayed documentation should be made and presented to him with evidence of the direct negative impact his delayed notations have on his revenue.

I would *not* recommend that he simplify his dictation in order to circumvent the basic problem, which is that he is not completing his documentation in a timely fashion.

Billing based on time for circumstances when counseling/coordination of care comprises >50% of total face-to-face time should be the exception, not the rule. 

F Tessa Bartels, CPC, CPC-E/M


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## mkj2486 (Aug 7, 2008)

I agree that coding based on time would be the exception not the rule.  To bill a 99215, I would think the payor is going to want to know what the providers needs to discuss for that length of time with the patient, and it should be something serious. In my opinion, you would have to have proper documentation on what counseling the patient received, I am sure that the payor would deny a 99215 if your only basis is the time without important details.


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## dmaec (Aug 8, 2008)

since it's apparent you already know/knew the time factor rules when you posted your question, I won't reiterate them  BUT -to answer your question, "would this be enough documentation to bill a 99215?"  I don't believe a little blurb like in your example below for the level 5, would justify a level 5.

In the scenario you've presented, I believe very strongly that it would be wrong to bill for this troublesome provider using the "time factor". The real issue is the physician -not the coder or coding! 
_{that's my opinion on the posted matter}_


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