Counseling and/or coordination of care vs. key elements


Ann Arbor, MI
Best answers
Here's a hypothetical situation to illustrate my question:

An initial inpatient service is performed by a doctor who documented a comprehensive history, comprehensive exam, and high complexity MDM. The provider also documented, "65 minutes spent face to face with patient, greater than 50% in counseling." Assuming the doctor's documentation met all criteria for detailing the extent of the counseling performed, which would you go with to determine the E/M? The key elements which qualify for 99223 or the time which qualifies for 99222?

I have seen where WPS has said, "Code the service based on the three key elements and then on time when counseling/coordination of care is an option. Then you want to choose the procedure that is most advantageous to you," but unfortunately that's not the relevant MAC here and I've been unable to find anything so concrete from a more neutral, but just as definitive, source.

Does anyone have a trusted source that they could share with me that details how to make that determination? Thanks in advance.