Podiatry Coding & Billing Alert

Here’s the right way to make every second count.

Ever since January 2021, you’ve had the option of assigning levels to office/outpatient evaluation and management (E/M) visits to your practice either using medical decision making (MDM) or time. But questions still remain over the correct way to count time for 99202-99215 (Office or other outpatient visit for the evaluation and management of a new/established patient …).

Now, in 2023, learning how to code time accurately has become even more important, as CPT^® has brought other E/M services, such as 99242-99245 (Office or other outpatient consultation …) and initial, subsequent, and same day admission and discharge hospital care codes 99221-99223, 99231-99233, and 99234-99236, in line with the way you calculate levels for 99202-99215.

Here, then, are some key dos and don’ts to help you count time for E/M visits correctly.

Do Understand Which Activities Count Toward Time

Per the 2023 CPT^® guidelines, the full list of activities that you can include in total time includes:

• “Preparing to see the patient (eg, review of tests)
• “Obtaining and/or reviewing separately obtained history
• “Performing a medically appropriate examination and/or evaluation
• “Counseling and educating the patient/family/caregiver
• “Ordering medications, tests, or procedures
• “Referring and communicating with other health care professionals (not separately reported)
• “Documenting clinical information in the electronic or other health record
• “Independently interpreting results (not separately reported) and communicating results to the patient/ family/ caregiver
• “Care coordination (not separately reported)”

“One of the most common misconceptions on reporting an E/M based on time is that a provider is required to document the time spent on each specific task associated with the visit,” says Donna Walaszek, CCS-P, billing manager, credentialing/ coding specialist for Northampton Area Pediatrics LLP in Northampton, Massachusetts. The provider needs to instead document the total time personally spent on the above-listed activities on the date of the encounter.

Note: Total time does not include time for activities the clinical staff normally performs. Also, be sure to review and apply the CPT^® guidelines for a shared or split visit. For example, if a patient comes in for a follow-up and sees a nurse practitioner (NP), that NP is going to start to evaluate any new patient complaints. Then the patient would likely consult with your podiatrist about the problem and a new treatment plan.

“The time they spent in the room together is going to count only once. So, if the nurse practitioner spent 10 minutes with the patient, then invites the podiatrist in and they spend 15 more minutes together, it’s going to be a total of 25,” said Rae Jimenez, CPC, CDEO, CIC, CPB, CPMA, CPPM, CCS, senior vice president of products at AAPC in “Risk Associated with Coding Time,” her recent presentation at HEALTHCON Regional 2022.

Don’t Round Up Time

It might not seem like a big deal to round up a few minutes on each encounter, turning 16 minutes into 20, or 25 into 30. It is easy for your podiatrist not to pay close attention to their watch. But when physicians round up on every patient, it has a dramatic effect by the end of the day. Adding an extra five minutes to each patient could end up looking like your podiatrist spent hours longer at the practice than they really did.

Inflating time, whether intentional or not, is something practices should avoid. More, “you don’t want the time to look the same for every single patient,” cautioned Jimenez.

Do Document Related Services Outside the Office

Some services are billable but don’t get counted for time when they should. This would be the case when your provider documents how many minutes they spent with the patient, but the provider doesn’t include the time spent preparing to see the patient. This is common for physicians who are still accustomed to documenting in-office visits based on face-to-face time.

Remember, “the AMA defines time for E/M coding as the total time (based on minutes) the provider spends on the date of service during which a provider personally rendered services related to the patient’s care, even if the times are not consecutive,” explains Walaszek. So, sometimes what happens is physicians forget to document all of their time.

As long as those services are accounted for in the record and are performed on the same day (for example, reviewing X-rays after the encounter), you can justify that time.

Don’t Skew Reporting of Other Billable Services

Alternatively, be careful not to count services twice. For example, for many minor surgeries, the E/M is built into the CPT^® code payment for the procedure, so carving out time spent there would result in your podiatrist getting paid twice for the same service. Pay close attention to which procedure codes include the E/M, and you’ll be sure not to make that mistake. Also, pay close attention to the documentation. “If the physician is performing other billable services, add a note that says, ‘total time is 20 minutes excluding other billable services,’ so that in an audit there is no question,” said Jimenez.

Do Be Confident About Time-Based Leveling

Using time to level an encounter is perfectly legitimate — and it’s often in your podiatrist’s best interest to code this way. The documentation has to be precise, though, to justify the time spent. When auditors perform time-based audits, “they will look at your schedule for the day and see how much time was worked, then total up all your visits. If you coded based on time and those hours add up to 20, but the actual hours worked was only 10, that doesn’t add up,” said Jimenez.

Fixing these issues before they become bigger issues might be a matter of more precise time reporting. Rounding up, forgetting to document same-day out-of-office time, and misrepresenting other billable services will all lead to inconsistencies during an audit. The best thing to do is study the patterns of the practice and see if there are any anomalies. As always, be sure to keep an open line of communication between coding personnel and physicians to identify and resolve issues.