# Time Statements - guidance/input on appropriate



## wrangel2 (Feb 2, 2015)

I am looking for some guidance/input on appropriate time statements when a visit is dominated by counseling and coordination of care. Our practice has asked our physicians to state time in the following manner:"Total visit time today was 30 minutes with greater than 50% spent in counseling and/or coordination of care." 

Inevitiably they will get creative with their time statements and end up stating time something like this:"We spent at least 30 minutes in direct conversation and all that time was spent discussing diagnosis, treatment and management options."

If they document the extent of their counseling/coordination of care and the encounter is truly dominated by this, is it okay to state time in this manner, or is it absolutely necessary to use the words counseling/coordination of care in their time statements?

I appreciate any feedback. Thank you!


----------



## jdibble (Feb 9, 2015)

wrangel2 said:


> I am looking for some guidance/input on appropriate time statements when a visit is dominated by counseling and coordination of care. Our practice has asked our physicians to state time in the following manner:"Total visit time today was 30 minutes with greater than 50% spent in counseling and/or coordination of care."
> 
> Inevitiably they will get creative with their time statements and end up stating time something like this:"We spent at least 30 minutes in direct conversation and all that time was spent discussing diagnosis, treatment and management options."
> 
> ...



We have the same issue with our physicians, trying to be creative! (They do the same thing for the ROS when we tell them to simply say "all others are negative" they try to say it differently such as "10 point review negative" which we have to tell them cannot be counted as a complete ROS.)

I would hesitate to accept the way you have demonstrated that they document the encounter because they do not indicate the "total" time of the visit. We advise our physicians that in order to bill based on time, they need to include the total time with the statement that more than 50% of the time was spent...(insert description of discussion). We also require that they at least document the HPI and some sort of brief exam. (constitutional, psych, skin, etc.)

CMS states: "if the physician documents total time and suggest that counseling or coordinating care dominates (more than 50%) of the encounter, time may determine the level. Documentation may refer to: prognosis, differential diagnosis, risks, benefits of treatment, instructions, compliance, risk reduction or discussion with another health care provider."

Therefore, I would make sure that they at least include the total time with the 50% statement in their documentation.

Interested in others opinions on what they allow!


----------



## Lyta2000 (Feb 9, 2015)

I'm on the payor side and won't except it if it doesn't give total face to face time and state that greater than 50% was spent in counseling. They must then tell what was discussed. It is very easy to get paid for when they don't get creative.


----------



## Pam Brooks (Feb 10, 2015)

"I spent 35 minutes with the patient, and greater than 50% of that time was spent in counseling her about the possible complications of uncontrolled diabetes.  We discussed dietary changes, exercise and monitoring of blood sugars.  I explained the various complications such as vascular disease, renal and opthalmological issues and neurological problems, and what that would mean to her quality of life.  She verbalized understanding and we made a plan to meet in two months to review her progress." 

It's one thing to state the face-to-face time and to indicate that counseling dominated the discussion.  But there has to be some credibilty to the statement with further documentation of the actual discussion.  This illustrates the medical necessity of that large chunk of counseling time.  And as we know, it's all about the medical necessity!!


----------



## TTcpc (Feb 12, 2015)

I educate using the same phrase template that Pam refers to her in post.  "I spent greater than 50% of this (total time) visit in counseling/coordination of care with the patient (and anyone else else involved in the discussion such as family/POA/guardian/other healthcare providers) regarding (brief description of what was discussed)"  The creativity of my physicians often comes in when they state refer to assessment/plan of care instead of giving a brief description; however if it is clear enough in their assessment/plan of care then I just re-educate on making sure the necessity is clear.  Our Medicare carrier (Novitas) even has a time statement score area on their E/M audit sheet that goes so far as to state that "counseling or coordinating care dominates greater than 50% of the visit".  In addition it states that all three score questions must be answered "yes" regarding: documentation of total time, description of content of counseling/coordination of care, and that more than half of the time was spent in counseling and coordination of care.  Given these three things, I have not been very lenient in allowing them to document otherwise.


----------

