All that fine green print on time in your E/M CPT 2011 manual boils down to one thing: you can round to the closest time code.
But that advice from CPT contradicts Medicare’s threshold time guideline.
CPT Treats Times as Averages
CPT 2011 indicates you can use the code closest to the documented time. That advice is nothing new. “In selecting time, the physician must have spent a time closest to the code selected,” states CPT Assistant, Aug. 2004.
Your documented time must equal or exceed the average time given to bill that level. For a 35 minutes spent on a medically necessary counseling-dominated visit is a 99214, per CPT you could report 99215.
Medicare Has Considered Times Thresholds
Medicare has always considered the times indicated in CPT’s code descriptors to represent minimums. The physician would select the lower code (for instance 99214, … physicians typically spend 25 minutes face-to-face with the patient and/or family …) unless the time was greater than or equal to the higher-level code’s required time (such as 40 minutes for 99215).
Will Medicare Change Its Position?
At the CPT® and RBRVS 2011 Annual Symposium when questioned on whether Medicare would change the allotments from thresholds to averages, medical directors were reluctant to give a definitive answer. “I don’t want to say one way either ‘Yes’ or ‘No’ at this time,” said E/M expert Deborah Patterson, MD, clinical medical director for Trailblazer Health Enterprises, LLC in Dallas.
To see if CMS delivers a definitive answer, mark your calendar for the Dec. 23 webinar “2011 E/M, Vaccines and Time Based Codes – CPT Coding Update” by Jen Godreau, BA, CPC, CPMA, CPEDC.
