Overlapping Time Spent Documentation between multiple patient encounters for same provider

Create Wiki
M

MarissaCharlesworth

New
Messages
8
Location
Grants Pass, OR
Best answers
0
I was reviewing a providers encounters for one DOS and noticed she was overlapping time spent documentation. Example.: Patient A has documented time spent from 8:05 to 8:45 and Patient B has documented time spent from 8:40: to 9:10 etc etc. When I brought this to her attention and tried explaining why overlapping was inappropriate, she claimed that she is multitasking working on two patient notes for 2 separate encounters at the same time. Is this appropriate? How do I explain it better for the provider to understand the risk of this?
 
Each minute can only count for time spent on one particular patient. The time does not need to be continuous, but cannot count for multiple patients simultaneously. Multitasking really means your are switching between tasks. It is physically impossible to chart 2 different patient notes at the exact same time.
I have not seen requirements to state the actual time, only the actual minutes. For example, many providers spend some time before seeing patients for the day "prepping" for the first couple of patients. Then spend lunch completing documentation or prepping for afternoon patients. And after seeing patients for the day, spend time at the computer charting/orders/etc.
So Patient A might be 40 minutes, but was really 8:05a-8:27a, then 8:43a-8:53a, then 12:02p-12:10p. Patient B might be 30 minutes as 8:40a-8:42a, 8:54a-9:10a, 11:42a-11:50a. It is NOT necessary to track the time that way. You'd have to walk around all day with a stopwatch.
Or if the note said "spent 27 minutes intermittently from 8:05a-8:45a.....", I would find that acceptable as you are not counting all 40 minutes. But again, not necessary.
From AMA guidelines:
For coding purposes, time for these services is the total time on the date of the encounter. It includes both the face-to-face time with the patient and/or family/caregiver and non-face-to-face time personally spent by the physician and/or other qualified health care professional(s) on the day of the encounter (includes time in activities that require the physician or other qualified health care professional and does not include time in activities normally performed by clinical staff). It includes time regardless of the location of the physician or other qualified health care professional (eg, whether on or off the inpatient unit or in or out of the outpatient office). It does not include any time spent in the performance of other separately reported service(s).
Physician or other qualified health care professional time includes the following activities, when performed:
■ preparing to see the patient (eg, review of tests)
■ obtaining and/or reviewing separately obtained history
■ performing a medically appropriate examination and/or evaluation
■ counseling and educating the patient/family/caregiver
■ ordering medications, tests, or procedures
■ referring and communicating with other health care professionals (when not separately reported)
■ documenting clinical information in the electronic or other health record
■ independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver
■ care coordination (not separately reported)◄
Do not count time spent on the following:
■ the performance of other services that are reported separately
■ travel
■ teaching that is general and not limited to discussion that is required for the management of a specific patient

I also stand by my overall belief that for most physicians/specialties/patients, you can reach a level of service by MDM in less physician time than the time descriptors. Appropriately trained/utilized staff and appropriate use/customization of EHR systems would not typically take a clinician 30 minutes of CLINICIAN time to order 3 tests and renew a prescription for a patient with stable elevated cholesterol. There are always exceptions, but when I see a clinician coding every visit based on time, it makes me suspicious.
 
What type of service is it? E/M or time based, face-to-face type like psychotherapy or other therapy?

As Christine said. You can't physically work on 2 notes at the exact same time. If you took a day of the provider's notes (if E/M): is every visit coded by time? If you logged them in a spreadsheet with the times listed does every one overlap? It's impossible.
I agree, it does not have to be documented minute by minute like a stopwatch, but they cannot overlap. If you go to the CPT guidelines (if talking E/M), read the last sentence of paragraph 4 under Guidelines for Selecting Level of Service Based on Time: "It does not include ant time spent in the performance of other separately reportable services." In this case they are claiming time spent in another separately reportable service. Also, if you looked at their schedule compared to all the time claimed during one day, would it be physically impossible to claim all of that in one day with the # of patients and time spent? Did they also claim time based somewhere else like the hospital or in a surgery or procedure room at the same time? Things to look at depending on practice type.

Provider is going to run into impossible and overlapping time issues/red flags. They are putting themselves at risk by this behavior. Especially if they are doing it to bump up to a higher E/M level by crossing the time threshold! In your example above, depending on new v. established that 5 extra minutes makes a level difference if the E/M was coded by time. It's misrepresenting the time to up-code.
You could try to show them this from AMA: https://www.ama-assn.org/system/files/regulatory-myths-doc-coding-em.pdf (The CPT® E/M Guidelines include discrete, non-overlapping time spend ranges within the code descriptors correlating to LOS codes.)
 
You must log in or register to reply here.
Top