Yes you can (with correct documentation)!
Hello,
I am not sure if you are still looking for an answer to this, but here goes:
CMS Claim Processing Manual says Chapter 12 30.6.1.C
"Advise physicians that when counseling and/or coordination of care dominates (more
than 50 percent) the face-to-face physician/patient encounter or the floor time (in the case
of inpatient services), time is the key or controlling factor in selecting the level of service.
In general, to bill an E/M code, the physician must complete at least 2 out of 3 criteria
applicable to the type/level of service provided. However, the physician may document
time spent with the patient in conjunction with the medical decision-making involved and
a description of the coordination of care or counseling provided. Documentation must be
in sufficient detail to support the claim."
Time when documented correctly, can be used as the overriding factor for an E/M level, however there must still be major E/M elements in the note as described in the Claims Manual excerpt above.
Hope this helps!
