Code Patient Portal Discussions With Virtual E/M Rules in Mind
Question: A provider asked me about possibly billing a lengthy patient portal exchange with an established patient. The patient described ongoing symptoms, and the provider reviewed the record, discussed next steps, ordered testing, adjusted treatment, and sent several follow-up portal responses over the next few days. Can the provider bill this work, and if so, which code should we use? Missouri Subscriber Answer: This situation may be billable, but not every lengthy portal thread can be reimbursed. The key determination to make is whether the exchange represents evaluation and management (E/M) work performed by a provider or other qualified healthcare professional (QHP) for an established patient. The exchange should also be patient-initiated. If these circumstances apply, then you can count the physician’s or other QHP’s cumulative time for the episode during the 7-day window, including medically necessary review of the patient’s inquiry, relevant record review, assessment, care planning, test or medication orders, and related communication back to the patient, and report one of the following codes based on the provider’s cumulative qualified time during the 7-day period: Important: Coders should not separately report online digital E/M if the portal exchange is related to an E/M service performed within the prior 7 days or results in a separately reportable E/M service within the next 24 hours or soonest available appointment. Additionally, these codes are inappropriate for routine administrative messages, refill requests without evaluation, normal test-result notifications without interpretation or management, scheduling issues, or clinical staff-only work — these codes are meant to reflect genuine E/M services. Remember, before you bill, verify payer policy, consent requirements, and any cost-sharing or patient-notice rules. To proceed with billing, you can ask the provider to document the cumulative qualified time, the clinical issue addressed, the assessment and management performed, and any orders or treatment changes. The note should support why the portal exchange required professional E/M work and why the selected time-based code was appropriate. Rachel Dorrell, MA, MS, CPC-A, CPPM, Production Editor, AAPC
