Wiki Time based coding and separately reported services 2021

[arkassabaum]

When considering time now in 2021, is it necessary to carve out separately reported services?? For example the GAD7 and PHQ9 are charged separately. We have one staff member questioning if we should now include that in time and bundle it into the e/m. Initially, I do not agree. Separately reported to me means you can still do it in the total time of the visit, it just isn't included in the level. Therefor, any service separately reported by CPT is not included in time. Making a provider "carve" that out of total time seems overkill.

Does anyone have a solid reference to support this? I have reference from AMA/CPT that define what is included in time, but I am looking for something specific to the above scenario.

 

[csperoni]

While I know I have seen that time spent on separately reported codes is not counted, I couldn't find an official AMA or CMS reference to support this. It may exist, I just didn't have it in my saved references. It's kind of implied, and assumed, but I did not see it specifically stated except on an AAPC post. I would call that a solid reference, even though not directly "from the horse's mouth".

https://www.aapc.com/evaluation-management/em-codes-changes-2021.aspx (my emphasis added on the relevant point).
A key shift for the office and other outpatient E/M codes is that the time referenced in the 2021 code descriptors is total time. The 2020 descriptors for these codes used intraservice time.

• The 2021 Time guidelines explain that for 99202-99205 and 99212-99215, total time on the encounter date includes both face-to-face and non-face-to-face time spent by the provider.
• The guidelines offer the examples of preparing for the visit (such as reviewing tests); getting or reviewing a history that was separately obtained; performing the exam; counseling and providing education to the patient, family, or caregiver; ordering medicines, tests, or procedures; communicating with other healthcare professionals; documenting information in the medical record; interpreting results and sharing that information with the patient, family, or caregiver; and care coordination.
• When you count time for the 2021 codes, you should not include time spent on services you report separately. For instance, if you report care coordination using a separate CPT® code, you should not include that service’s time in the time for the E/M code.
• The total time also does not include time for activities the clinical staff normally performs.

 

[TL@zo]

For 2021 E&M in regards to "activities the clinical staff normally performs". Does the AMA or CMS define somewhere what they consider "activities the clinical staff normally performs" ?