Podiatry Coding & Billing Alert

Question: If the physician documents: "Time spent in the evaluation of the patient with mostly medical decision making time (two thirds) is 75 min" can I choose the E/M code based on time alone?

Nevada Subscriber

Answer: No, you cannot code based on time with just the documentation you have mentioned.

Here's why: You should only code an E/M service based on time alone if at least 50 percent of the visit was spent on counseling or coordination of care.

How it works: According to this year's CPT manual, you can use the code closest to the documented time. "If coding by time, pick the closest typical time," said Peter Hollmann, MD, during the "E/M, Vaccines, and Time-Based Codes" session at the CPT and RBRVS 2011 Annual Symposium in Chicago this past fall.

That advice echoes previous AMA information. For instance, the August 2004 CPT Assistant stated, "In selecting time, the physician must have spent a time closest to the code selected."

Your documented time must equal or exceed the average time given to bill that level. For a 35 minute visit spent on a medically necessary counseling-dominated visit, per CPT you could report 99215 (Office or other outpatient visit for the evaluation and management of an established patient ... Physicians typically spend 40 minutes face-to-face with the patient and/or family).

Keep in mind: CPT notes that "this includes time spent with parties who have assumed responsibility for the care of the patient or decision-making, whether or not they are family members (for example, foster parents, person acting in loco parentis, legal guardian."

Caveat: Be careful when reporting 99215 based on time only, as Medicare tends to frown on podiatrists reporting that code, say experts.

Remember that although the AMA, via CPT Assistant, directs you to code based on the "closest" time, most Medicare payers have always considered the times indicated in CPT's code descriptors to represent minimums. Under those regulations, the physician would select the lower code (for instance 99214, ... physician typically spends 25 minutes face-to-face with the patient and/or family ...) unless the time was greater than or equal to the higher-level code's required time (such as 40 minutes for 99215).