Minimum time required to bill moderate sedation up to first 30 mins 99144


Carolina Beach, NC
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I am getting mixed reviews on the time required for mod sed in order to bill 99144 (first 30 mins). per CPT, for time based codes, greater than 50% is required which in this case it would be 16 mins of mod sed needed to bill, however, I've been advised by some that this rule does not apply with "first" and "up to" codes. Meaning, if the description were moderate sedation 30 mins, then the above rule would apply, but because it is worded "first 30 minutes" then any duration of mod sed would qualify. I can't find anything on CMS or AAPC (may not be looking hard enough) but I did find something on this site (, but not sure if it's a trustworthy source. Also, did not find the citation of their source (AMA) to have stated this, and even if they have, what is their source? Any insight greatly appreciated! I'm leaning toward having to meet 16 mins, just based on the lack of info out there, and using the standard time guidelines in the CPT, however, I do think that a provider could easily appeal something like this if not written specifically in a policy. Thoughts?
The following is from the October 2011 CPT Assistant:
Question: Is it appropriate to report the moderate (conscious) sedation codes for the first 30 minutes of intraservice time if only 10 minutes of moderate sedation services are provided?
Answer: No. The standards for time measurement provided in the Introduction of the CPT 2011 codebook shall apply unless there are code or code-range-specific instructions in guidelines, parenthetical instructions, or code descriptors to the contrary. As there are no code or code-range-specific guidelines for the moderate (conscious) sedation codes, the general guidelines are to be applied. A unit of time is attained when the midpoint has been passed. Therefore, in order to report a code with a unit of time of 30 minutes, 16 minutes or more of the service described by the code must be provided. If the time threshold has not been met, then the code is not reportable.

Note that the moderate sedation codes are changing in 2017.