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Using Time to Code E/M

Starting in 2011 there is a new explanatory paragraph on Time, as it relates to CPT© coding. Here you'll find essential time information. Unless there are code or code-range-specific instructions in guidelines, parenthetical instructions, or code descriptors to the contrary:

• Time is face-to-face with the patient.

Note that many inpatient services, as well as subsequent observation care 99224-99226 (technically an outpatient service) define time as bedside or floor/unit time. This is one case where descriptor-specific instructions override general guidelines.

• Phrases such as "interpretation and report" in the code descriptor are not intended to indicate in all cases that report writing is part of the reported time.

• A unit of time is attained when the mid-point is passed.

As an example, critical care services (99291-99292) are time based, with 99291 Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes reporting the first hour of critical care. To report 99291, the length of service must exceed the "half-way" mark, or at least 31 minutes. Critical care lasting fewer than 31 minutes is reported using an appropriate evaluation and management (E/M) code, rather than 99291. Similarly, +99292 Critical care, evaluation and management of the critically ill or critically injured patient; each additional 30 minutes (list separately in addition to code for primary service) reports "each additional 30 minutes" of critical care, in excess of the first hour. This means that to report +99292, at least 75 minutes of critical care must be documented (60 minutes for the first hour, plus at least 15 minutes-the "halfway mark"-to report the additional 30 minutes of critical care as reported by +99292).

• When codes are ranked in sequential typical times and the actual time is between the two typical times, the code with the typical time closest to the actual time is used.

For instance, when reporting a time-based E/M service for an established outpatient, the documented counseling/coordination of care is 22 minutes. By CPT© standards, this would mean the proper coding is 99214 (Physicians typically spend 25 minutes face-to-face with the patent and/or family), rather than 99213 (Physicians typically spend 15 minutes face-to-face with the patient and/or family), because 22 is closer to 25 than to 15. Note that all payers agree with this rule. For example, the Centers for Medicare & Medicaid Services (CMS) typically views the E/M reference time as the minimum time needed to report a service.

• When another service is performed concurrently with a time-based service, the time associated with the concurrent service should not be included in the time used for reporting the time-based service.

Time spent performing separately-reported services concurrent with critical care services 99291-99292 may not be counted toward critical care time. The Evaluation/Management (E/M) Services Guidelines also have undergone revisions for 2011 to clarify better how time relates to E/M services.

 

A summary of the additions include:

• Verification that non-face-to-face (pre- and post- encounter) time may not be included when calculating total time for an office service.

• Notification that the total work of E/M services has been calculated to include non-face-to-face time.

• A restatement that time shall be considered the key factor for E/M leveling, when counseling and coordination of care dominate the encounter.

• A determination that counseling or coordination of care includes time spent with patients or those individual(s) (including non-family members) who have assumed responsibility for the patient.

• A requirement that the extent of counseling and/ or coordination of care must be documented in the medical record.

• Advice to report add-on codes for prolonged E/M services.
 

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