Neurology & Pain Management Coding Alert

CMS, CPT^® still split on when you can code for extra time.

In the last few years, the Centers for Medicare & Medicaid Services (CMS) has changed how you’ll code prolonged services in more than one way.

Things are getting tricky for prolonged service coding. CMS implemented more changes to prolonged service coding with the 2023 final rule. And, to make matters more confusing, Medicare and payers who follow CPT^® guidelines can’t agree on how to code for prolonged services.

Don’t worry: We’ve gotten the lowdown on the new codes, and coding conventions, that are part of prolonged services coding in 2023. Here’s what the experts had to say.

Know the New +99417 Descriptor

For 2023, CPT^® removes the words “beyond the minimum required time” from the descriptor for +99417, which now reads (Prolonged outpatient evaluation and management service(s) time with or without direct patient contact beyond the required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time (List separately in addition to the code of the outpatient Evaluation and Management service)).

Fortunately, the guidelines for using the code remain the same. CPT^® instructs you to use +99417 when service times for 99205 (Office or other outpatient visit for the evaluation and management of a new patient … 60-74 minutes of total time is spent on the date of the encounter) or 99215 (Office or other outpatient visit for the evaluation and management of an established patient … 40-54 minutes of total time is spent on the date of the encounter) go 15 minutes beyond the minimum for the 99205/99215 time ranges — 75 minutes for a new patient visit and 55 for an established patient — and additional units for every 15 minutes beyond those times.

Keep Up With +99417 CPT^® Updates

For 2023, CPT^® also deletes prolonged service codes +99354 and +99355. In their place, you’ll now use +99417, as CPT^® has increased its scope. You’ll now be allowed to use it to report prolonged services with:

• 99245 (Office or other outpatient consultation for a new or established patient …) when the time meets or exceeds 55 minutes
• 99345/99350 (Home or residence visit for the evaluation and management of a new/established patient …) when the times meet or exceed 75 or 60 minutes, respectively
• 99483 (Assessment of and care planning for a patient with cognitive impairment …) when the service goes beyond its typical time of 50 minutes

Don’t Forget +99218

CPT^® also deletes prolonged service codes +99356 and +99357 for 2023 and introduces another code: +99418 (Prolonged inpatient or observation evaluation and management service(s) time with or without direct patient contact beyond the required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time …), which had been previously give the placeholder code of 993X0.

In addition to the highest-level initial and subsequent nursing facility care E/M codes 99306 and 99310, you’ll use +99418 with the following revised codes:

• 99223 (Initial hospital inpatient or observation care … 75 minutes must be met or exceeded)
• 99233 (Subsequent hospital inpatient or observation care … 50 minutes must be met or exceeded)
• 99236 (Hospital inpatient or observation care … 85 minutes must be met or exceeded)
• 99255 (Inpatient or observation consultation … 80 minutes must be met or exceeded)

Use G Codes for Medicare Payers

In the 2021 final rule, CMS argued that you should use +99417 when the total time for visits hits 15 minutes beyond the maximum time range for 99205 (i.e., 89 minutes) and 99215 (i.e., 69 minutes). To avoid potential confusion with CPT^® guidelines, CMS created a new prolonged service code, recognized by Medicare and payers following Medicare payment rules, to take its place: G2212 (Prolonged office or other outpatient evaluation and management service(s) beyond the maximum required time of the primary procedure which has been selected using total time on the date of the primary service; each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact …).

For the 2023 final rule, CMS has taken a similar view of +99418, believing that the billing instructions for the code “would lead to administrative complexity, potentially duplicative payments, and limit our ability to determine how much time was spent with the patient using claims data.” In its place, they have introduced three more G codes:

• G0316 (Prolonged hospital inpatient or observation care evaluation and management service(s) beyond the total time for the primary service … each additional 15 minutes …) for prolonged inpatient or observation E/M service codes 99223, 99233, and 99236
• G0317 (Prolonged nursing facility evaluation and management service(s) beyond the total time for the primary service … each additional 15 minutes by the physician or qualified healthcare professional …) for prolonged nursing facility E/M service codes 99306 and 99310
• G0318 (Prolonged home or residence evaluation and management service(s) beyond the total time for the primary service … each additional 15 minutes …) for prolonged home or residence E/M service codes 99345 and 99350

Check Out This Clinical Scenario

First, consult the Clip & Save guide elsewhere in this article, then determine how you would code for inpatient care lasting 95 minutes for a patient who has just been admitted to the hospital.

If the patient has private insurance, you would bill 99223 and +99418 as “+99418 may be used as soon as the total time [75 minutes] has been exceeded by 15 minutes,” according to Kelly Loya, CPC, CHC, CRMA, CPhT, CHIAP, associate partner at Pinnacle Enterprise Risk Consulting Services, Charlotte, North Carolina.

However, for a Medicare patient, you would not be able to bill 99223 with G0316 in this situation as even though 99223 may have been exceeded by 15 minutes, the code’s descriptor tells you not to report G0316 “for any time unit less than 15 minutes.” In this case, the unit of the prolonged service time, 5 minutes, is less than 15 minutes, so you will only bill Medicare for the 99223 service.