Urology Coding Alert

New typical time assignments will mirror subsequent observation codes.

When CPT Codes 2011 debuted the subsequent observation care codes CPT 99224 -CPT 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 (Initial observation care, per day, for the evaluation and management of a patient ...) did not have typical times.

Good news: The new edition of your CPT® manual, which takes effect on Jan. 1, 2012 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, as was introduced on the 2011 subsequent observation care codes, says Gabrielle K., claims assistant for a practice in East Setauket, NY.

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 says.

How it works: According to CPT®, you'll use the inpatient prolonged service codes +99356-+99367 (Prolonged physician service in the inpatient setting, requiring unit/floor time beyond the usual service ...) when you bill initial (99218-99220) or subsequent (99224-99226) observation codes, says Michael A. Ferragamo, MD, FACS, clinical assistant professor of urology at the State University of New York at Stony Brook.

Warning: Medicare, however, will not reimburse for any prolonged service codes when billed with observation codes. On the other hand, CPT® rules indicate you may code this way and be paid, but again, remember Medicare will not pay you. Therefore, take note of the payer you are billing before adding 99354-99357 to your observation claims.

Bonus: "You can use prolonged services codes +99354-+99357 (Prolonged physician service ...) when billed not only by the physician, but now in 2012, also by other qualified healthcare professionals which include the non-physician providers, like physician assistants (PA) or nurse practitioners," Ferragamo says. "This information has come out now at the end of the 2011 year," he adds. "This is something you need to know for proper coding in 2012."

Inpatient Guidelines Means You Can Count Non-Face-to-Face Time

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 as noted above. 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, experts say. "I do believe it to be a positive step in the use of time-based coding for observation services," Gabrielle says. "I say this because it allows for the time spent outside of straight face-to-face time spent."

Remember: Inpatient time criteria includes 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, Gabrielle reminds. "I think it is a good thing to count time spent at bedside and on hospital floor or unit," she adds. "I work for a surgeon and while he may end up for many consecutive hours in the operating room, he is still reachable when it comes to a nurse on the floor or other physician needing to reach him in regards to test results and or findings. He is constantly back and forth from the OR to the floor reviewing and writing orders for his patients. To be able to use this prolonged service time instead of face-to-face time allows him to code more appropriately for his time."