Defining Face to Face services

cchenel

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Can someone please clarify if "Face to Face" means the patient must be present or is this "face to face" with family and/or patient? Since they removed the specific descriptors from the E/M codes there seems to be a debate on whether or not the patient needs to be present for 99212-99215's. I am interpreting "face to face" as time with patient and non face to face as time coordinating care etc. Please help!
 

thomas7331

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Under Medicare's guidelines, if E/M services were coding using time when more than 50% was spent counseling/coordinating care. the time must have been face-to-face time with the patient. However, this rule is moot now since under the new 2021 guidelines the time used to determine an office E/M includes both face-to-face and non-face-to-face time spent by the provider on the day of the encounter.
 

cchenel

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Under Medicare's guidelines, if E/M services were coding using time when more than 50% was spent counseling/coordinating care. the time must have been face-to-face time with the patient. However, this rule is moot now since under the new 2021 guidelines the time used to determine an office E/M includes both face-to-face and non-face-to-face time spent by the provider on the day of the encounter.
Thank you for your response. The issue is that some coders I am hearing from are interpreting the new guidelines as not needing the patient present when billing based on time because they are using the "non face to face" verbiage as being able to bill time based without the patient present. I am looking for anything in writing that states "face to face" time means face to face with the patient and provider, not provider and family only.
 

thomas7331

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Thank you for your response. The issue is that some coders I am hearing from are interpreting the new guidelines as not needing the patient present when billing based on time because they are using the "non face to face" verbiage as being able to bill time based without the patient present. I am looking for anything in writing that states "face to face" time means face to face with the patient and provider, not provider and family only.
The Medicare guidance I referenced above is the only place I'm aware of where it states that face-to-face time requires face-to-face time with the patient, and as I said, that is now outdated because that guidance is given in the context of time used for counseling and coordination of care. I believe your coders are making the correct interpretation of the new guidelines, at least for purposes of office E/M coding.

There seem to be a lot of areas of confusion and grey areas with the new guidelines, and I imagine there will be clarifications issues in the coming months, so perhaps this will be one of those where additional guidance is given.
 

cchenel

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Thanks Thomas. Yes, I hope they will clarify because if coders interpret this as the patient not needing to present the providers may feel like they have free reign to bill visits without the patient ever being present citing the parent had face to face time which doesn't add up to good healthcare.
 

thomas7331

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Thanks Thomas. Yes, I hope they will clarify because if coders interpret this as the patient not needing to present the providers may feel like they have free reign to bill visits without the patient ever being present citing the parent had face to face time which doesn't add up to good healthcare.
I can certainly understand your concern, but on the other hand, having worked in various specialties I know that many providers spend an enormous amount of non-face-to-face time working on behalf of their patients in activities that are definitely necessary part of achieving 'good healthcare'. Under the old guidelines, very little of that could be captured in codes that would reimburse them for their time.

These new guidelines are just being rolled out and it's early to try to say what the costs and benefits of the changes will be, but over time we'll begin to see this and I'm sure there will need to be revisions.
 

cchenel

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Oh yes I don't disagree at all that so much of the time is not compensated for sure! I just don't want providers focusing on the non face to face time while forgetting about the face to face time with the patient. I think they are overlooking that it is face to face AND non face to face. They see it as OR and not both. Here's hoping for clarification soon that the face to face time does include "face to face time with patient".
Thanks again!
 
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