Providers always bill 30 minute services back to back. Audit Risk??


Cuyahoga Falls, OH
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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.
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Hi there, the main thing to remember is that if you're following payer guidelines and your documentation supports your coding an audit (if it happens) will be an annoyance but you practice will be fine.

In addition, the E/M office visit codes have time ranges so your claims will not indicate exactly how long each visit was.

Having said that, unusual billing patterns do attract attention and it looks like all of your new patient E/M visits will be level 3 and all established will be 4. But again, if your documentation is solid and if you are audited it will just be annoying.

I think the real risk here is that people may start to assume that every visit is 30 minutes and code based on that assumption. That could create over or undercoding.


True Blue
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Agree with If the records support the coding, you should be fine. The breaks in schedule to help you justify the times.
I will note it certainly would raise an eyebrow if I was auditing that every single patient took exactly 30 minutes. No one ever was 29 minutes? No one ever was 32 minutes? It would make me scrutinize the records a little more carefully looking for any suspicious coding.