I agree it does depend on documentation however:
CPT states, "When counseling and/or coordination of care dominates (more than 50%) the physician/patient and/or family encounter (face-to-face time in the office or other outpatient setting or floor/unit time in the hospital or nursing facility), then time may be considered the key or controlling factor to qualify for a particular level of E/M services." This means that time alone can be used to select a level of care, regardless of the extent of the history, exam or the medical decision making, if the majority of the encounter involves counseling or coordination of care. For E/M services, counseling may include a discussion of test results, diagnostic or treatment recommendations, prognosis, risks and benefits of management options, instructions, education, compliance or risk-factor reduction.
Therefore, this encounter was one hour - 45 minutes( over 50%) was spent couseling or coordinating care, therefore, if this was an established patient visit, yes 99215 can be used. Documentation must be very clear on what was discussed.