“Reference Time” a Must When Reporting E/M Counseling and Coordination of Care
When reporting E/M services by time (rather than the key components of history, exam, and medical decision-making), you should use CPT® “reference times” to determine an appropriate E/M service level. The reference time is stated in the final sentence of the CPT® E/M code descriptor (e.g., “Physicians typically spend 30 minutes face-to-face with the patient and/or family”). Reference time for established outpatient codes are:
99211 = 5 minutes
99212 = 10 minutes
99213 = 15 minutes
99214 = 25 minutes
99215 = 40 minutes
CPT® states, “When codes are ranked in sequential typical times and the actual time is between two typical times, the code with the typical time closest to the actual time is used.” For example, when reporting a time-based, established outpatient E/M lasting 19 minutes, you would report 99213.
A final consideration: Not all E/M service codes include reference times. For example, per CPT®, “Time is not a descriptive component for the emergency department levels of E/M services because emergency department services are typically provided on a variable intensity basis…,” according to CPT®. Likewise, observation codes 99234-99236 do not have a reference time. Because these services do not include reference times, they should not be reported with time as the controlling element.