Wiki TIME STATEMENT - SUBSEQUENT HOSPITAL VISITS

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bailsb

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Hi all,

I have a provider that puts this statement on a good majority of his/her subsequent hospital visit notes:

Discussed with patient times 26 minutes with questions answered.
Total time on floor is 50 minutes.

Of course this is just the last part of the MD's full progress note.

Is there any reason or argument against billing a 99233 based on time for this visit? There are some conflicting messages from different parties within my organization so I thought I would post this.

Thank you.
 
Hi there, the only argument against would be a payer policy that requires more specific documentation for time.

CMS has issued a rather vague statement on time-based documentation https://www.cms.gov/files/document/r11842cp.pdf:

G. Medical Review When Practitioners Use Time to Select Visit Level
Our reviewers will use the medical record documentation to objectively determine the medical necessity of the visit and accuracy of the documentation of the time spent (whether documented via a start/stop time or documentation of total time) if time is relied upon to support the E/M visit.
Click to expand...

The AMA has made it clear that providers are not required to document the time they spend on each activity on the date of the encounter. https://www.ama-assn.org/system/files/regulatory-myths-doc-coding-em.pdf

Also, I do wonder if your provider is aware they can also count non-floor time now?
 
The question brought up by my colleague was is the "floor time" dedicated to this patient. But, you have brought up two topics that I have argued repeatedly for the MD, CMS has issued a rather vague statement and AMA has made it clear that providers are not required to document the time they spend on each activity. To me, this statement does meet the requirements to level a 99233 and will continue to accept the statement until more specific guidance is provided.

I appreciate your response and resources you have provided. Much appreciated . Thank you.
 
I see. If the concern is the provider isn't devoting the full 50 to an individual patient, that does warrant more investigation, especially if the numbers are off. For example, the provider documents 50 minutes of floor time with every patient or with more patients than would fit in the total time they spent at the hospital.
 
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