Practice Management Alert

Pay attention to inpatient guidelines for coding help.

When CPT® 2011 debuted the subsequent observation care codes 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, even though the initial observation care codes 99218-99220 didn't have typical times.

Good news: The new edition of your CPT® manual, which takes effect on Jan. 1, will remedy that problem.

Get to Know the Time Designations

CPT® 2012 adds the following typical time guidelines:

• 99218 -- ...Physicians typically spend 30 minutes at the bedside and on the patient's hospital floor or unit
• 99219 -- ...Physicians typically spend 50 minutes at the bedside and on the patient's hospital floor or unit
• 99220 -- ...Physicians typically spend 70 minutes at the bedside and on the patient's hospital floor or unit.

The addition of typical times will open the door for coding based on time, consistent with the other codes in the observation care series.

Learn When You Can Bill Based on Time

"There are only two ways that you can use time as a basis for selecting an E/M code," 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. "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. 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.

The observation care codes are outpatient site of service, but time guidelines are based on unit time, using inpatient time requirements. When prolonged service codes are applied to observation codes, CPT® also directs that the inpatient prolonged services codes should be used. Therefore, time for observation and associated prolonged services would be floor time, more liberal than the face-to-face outpatient time requirements.

This is inconsistent and confusing, but is a positive step in the use of time-based coding for observation services. Inpatient time criteria includes reviewing time you spend reviewing the chart before you see the patient, talking to the nurse, reviewing test results, and other time on the unit that goes beyond outpatient face-to-face patient/physician time requirements.