donaldjr1969
Contributor
I work in a behavioral health facility and a several of our psychiatric APNs almost exclusively bill their services in perfect 30minute blocks with no gaps. 9:30 - 10:00, 10:00 - 10:30, 10:30 - 11:00, and so on. I realize that with the 2021 EM changes providers can document many (but not all) non face-to-face aspects of the encounter. But a colleague of mine raised some concerns that always having 30 minute services in asuch a fashion could be an audit risk. How can one include simple things like walking a client to and from the waiting room, etc? How does one even account for a restroom break?
My logic is that this is justifiable because while an appt may be at 10:00, the previous client could have left say 3-4 minutes prior to 10:00 but the provider is going over the documentation and finalizing the previous 9:30 - 10 service. At 10, the provider begins to open the notes of the current appointment while the client has checked in. The provider reviews any pertinent notes from the current appointment. Client is first seen face to face at 10:05. Client receives their exam and is finished at 10:26. Provider finishes documenting the encounter in the EHR until 10:30. At 10:30, he begins the process for the next client and so on. Mind you I am just offering a scenario for the times. Their documentation is thorough enough to support 30 minutes of both face to face and non face to face time.
It should be noted that there are gaps in time where a provider will go 30 minutes for a break or a 60 minute lunch. So the provider is NOT billing 30 minute blocks from the start of their day to the end.
Anyway, is this a serious audit risk? Or do consecutive 30 minute blocks of billed time in and of itself not cause an audit risk? I can understand that billing by time and getting a lot of 99214 codes generally get the UM letters we all know and love. But the providers in question even did this before the 2021 changes where one only needed 25 minutes of time with >50% counseling.
My logic is that this is justifiable because while an appt may be at 10:00, the previous client could have left say 3-4 minutes prior to 10:00 but the provider is going over the documentation and finalizing the previous 9:30 - 10 service. At 10, the provider begins to open the notes of the current appointment while the client has checked in. The provider reviews any pertinent notes from the current appointment. Client is first seen face to face at 10:05. Client receives their exam and is finished at 10:26. Provider finishes documenting the encounter in the EHR until 10:30. At 10:30, he begins the process for the next client and so on. Mind you I am just offering a scenario for the times. Their documentation is thorough enough to support 30 minutes of both face to face and non face to face time.
It should be noted that there are gaps in time where a provider will go 30 minutes for a break or a 60 minute lunch. So the provider is NOT billing 30 minute blocks from the start of their day to the end.
Anyway, is this a serious audit risk? Or do consecutive 30 minute blocks of billed time in and of itself not cause an audit risk? I can understand that billing by time and getting a lot of 99214 codes generally get the UM letters we all know and love. But the providers in question even did this before the 2021 changes where one only needed 25 minutes of time with >50% counseling.
