Initial and subsequent observation codes look a little more alike in 2012. Have you ever wished that CPT® would put a time guide on its observation codes? Then you're in luck as of Jan. 1, 2012, because the new manual offers specific typical times that relate to each of the initial observation care codes. Observation Time Guidelines Could Open Doors When CPT® 2011 debuted 99224-99226 (Subsequent observation care, per day, for the evaluation and management of a patient ...), many coders were left scratching their heads at the fact that those new codes featured typical times associated with them for professional fee claims, even though initial observation care codes 99218-99220 don't have typical times. CPT® 2012 remedies that problem with the addition of the following typical time guidelines: It's possible the addition of typical times could open the door for coding based on time. "There are only two ways that you can use time as a basis for selecting an E/M code: if counseling/coordination of care takes up 50 percent or more of the visit, and if the code has a typical time associated with it," says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a consulting firm in Tinton Falls, N.J. "So by these codes now having a time reference, it sounds like we may have a way to reference time used if counseling or coordination of care takes up at least 50 percent of a visit. In addition, this could open the door to collecting for prolonged service times if the time the doctor spends exceeds 30 minutes more than the allotted time, and the visit notes are documented as such," Cobuzzi adds.