General Surgery Coding Alert

Question: ’ve heard that if we’re reporting E/M services based on time in 2021, we can count time spent before and after the office visit when we select the code. Is that true?

Nebraska Subscriber

Answer: Under certain circumstances, you may count time spent before and after an office visit when you determine E/M level based on time in 2021.

Basics: Beginning in 2021, you can bill for office/outpatient E/M codes (99202-99205 and 99212-99215) based on time without needing to meet the current rule that 50 percent of the visit must be spent in counseling and coordination of care. Instead, you can calculate the total time spent on the visit, including non-face-to-face time used to prep for, conclude, and follow up on the encounter within certain parameters. Then you can align the code choice with the times listed in the codes.

CPT^® versus CMS: AMA training for how to use the new codes states, “Only the total time on the date of encounter should be counted. This does not mean 24 hours before or after the visit. The time that is counted is all the time on the calendar date of the encounter only.” On the other hand, in the 2021 Physician Fee Schedule proposed rule, CMS is basing the pricing of the codes on the AMA RUC-recommended times for the codes, which included survey respondents “total time spent the day of the visit, as well as any pre-and post-service time occurring within the timeframe of 3 days prior to the visit and 7 days after.”

Bottom line: Payers may have different guidelines for how to count time. Hopefully, clarification for the CMS expectations will come when the final rule is published later this year.