That's my point. It does support the 99215 but and I'll refer to a previous post in this forum, which states "Once they document the time with the counseling or coordination of care, you're obligated to code by that" Is this fact?
I don't necessarily agree with that, but you'd probably be better off verifying that with the payer. Let's back up, though - what you're saying, is that, in approximately 12 minutes (or less, the physician performed some combination of either a comprehensive history, comprehensive exam, and/or documented high MDM, then he spent the remaining half (or more) of the visit, in counseling/coordination of care?
That seems a little sketchy, but it's not impossible, so let's look at other factors. Did he document the content of the counseling/CoC? Simply saying that it happened isn't enough - he should have at least mentioned (either) what was discussed, or what he did, in regard to "coordinating" care with another provider, for that to count.
Secondly, what problem(s) was the patient being seen for? Are they in line with the type/severity of the clinical examples in Appendix C for 99215? Or do they fit better with the types of examples listed for 99214? (The biggest difference between the two, is the likelihood of imminent hospitalization, if the problem isn't immediately addressed - a level 4 is a serious/worsening problem, but typically the prognosis isn't as dire, as the kinds of problems that warrant a level 5.)
If you're still having a hard time deciding, look to where the documentation is the most detailed - if the History and MDM support a level 5, you might have enough justification to bill it - in that case, I would take it to the provider, and ask what they think. They're ultimately responsible for the code selection, and only they have the expertise to back up using a higher code.
I know that E/M guidelines say that when Counseling/CoC dominates the visit, that time becomes the controlling factor in selecting the level, but in a situation like this, if you could easily justify a higher level without basing the code on time, and the doctor's okay with it, you shouldn't be forced to accept a lower level of service, when a higher level would be warranted, and is technically supported by the documentation.
