Question Minimum time guidelines for E/M with psychotherapy (90833)?


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I’m wondering if other psychiatric offices have internal policies to suggest the minimum duration for an E/M when the add-on code for psychotherapy (90833) is also used. There is no official guideline. The CPT manual says only to first select the E/M level based on the key components, and that the time used to meet criteria for the E/M level may not be used for psychotherapy. In reality, when the documented psychotherapy time (minimum of 16 minutes) is subtracted from the total visit duration, is there a reasonable amount of time left to have met the key components of the E/M level? Our providers say they can establish medical necessity and perform the key components in less than the typical time stated for the E/M (15 minutes for 99213; 25 minutes for 99214). So, my question is – what is reasonable? In the recent AAPC webinar Behavioral Health: Guidelines for Passing an Audit, Jamie Taylor, CPB, gives an example that an 8 minute visit probably doesn’t warrant a 99214/99215. Would 8 minutes be reasonable for a 99213 (total visit duration of 24 minutes, with 16 minutes of documented psychotherapy)? What would be a reasonable total duration for a 99214 with psychotherapy? Thanks for any input.