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Wiki 99354 w/o counseling documentation?

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PVAzCPC

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Scenario:

99214 that meets key component criteria, but provider spent 60 min total with the patient (typical time for 99214 published by CPT is 25 minutes), no counseling documented.

Can I add on 99354 for the extra 35 minutes spent?

Any input/opinion is greatly appreciated

Thanks! :)
 
It is in my opinion that no you can not charge the additional time. If you are not coding by time... and that would be based on 50% of time + was on coordination and counseling of the patient you should stick to the 3 key components when detrming your code if time is not properly documented.
see page 16 of 1995 documentation guidelines. Also look at page 7/8 in CPT for the guidelines for time reporting.
 
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