Wiki Billing based on time

[lilleyea]

I was just wondering what the consensus is on whether this scenario would be allowable for billing based off of time. The patient is being seen for a subsequent inpatient visit. The doctor documents the interval history, an exam, and a lengthy assessment and plan. She then goes on to document this:

Per caring team, asked to clarify details of code status - extensive discussion with pt's daughters - in case of code/cardiac arrest - No CPR, No intubation. Ok med's (chemical code) and shock/defibrillation. In case of respiratory distress without code/cardiac arrest - ok to intubate short term for reversible conditions.

Verified with team - correct orders - should be DNR with above limits.

Awaiting transfer SDU.
Discharge planing SNF - care coordinator input.
Face to face discussion/coordination of care 40 min.​

So here the documentation shows that the face to face discussion/coordination of care was 40 minutes, which is shown to be separate from the rest of the visit and that the whole 40 minutes was spent in face to face discussion/coordination of care. Would this documentation be acceptable to bill based off of time?

 

[thomas7331]

Strictly speaking, you can't bill based on time with this because without knowing the total time of the visit, including the time spent in the history and exam portion, you can't determine whether or not the amount of time spent coordinating care exceeded the 50% of the total time. That said, I personally think this is a technicality, and as an insolated instance only the strictest of auditors would disallow this - common sense would say the provider has sufficiently documented the time to support a code that represents 40 minutes of work and should get credit for this. Most auditors I know would allow up to the code that represented the 40 minutes of time and also give feedback to the provider for future reference. This would not only help protect the provider from an adverse audit but could also get them additional reimbursement since the code level would be based on the total time spent, not just the portion spent in coordinating care.

 

[lilleyea]

Thank you for responding. That was also my take on it, however I am being told by my supervisor that the documentation is not sufficient to bill based on time. I just wanted to see if I was the only one who thought that way. Thanks!

 

[Lyta2000]

Who is asking for the clarification? Is the face to face time with nursing staff? That time isn’t billable - coordination of care don’t include floor staff or transition from one practice partner to another. To me the note isn’t clear as to go was really involved. Sounds like she did a lot of record or order review which does count.

 

[csperoni]

Wait - I thought for inpatient only, floor/unit time (spent on that patient) are included for total time. Even time spent reviewing the records and charting. In our hospital, the social work team is almost always involved in this process, and CSWs are "other qualified health care professionals."
I agree that the doctor's documentation could definitely use some clarification since it does not follow the letter of the law, but I too would bill this a 99233 based on time. And I would educate my doc for better documentation in the future.