It depends on how you are billing I guess. My thought is this. These codes are codes that can be audited on levels of HX, exam and MDM. They notes should be audited out to the correct level of service.
Now, if she wants to bill the level based on time, then no, her method of 20 min, etc is NOT sufficient. Please see page 4 of your CPT book. It defines how to code based on time. In a nutshell, she has to state the total minutes spent with patient and out of those total minutes, how many were spent face to face counseling and coordinating care. She also has to state the nature of the counseling (ie. what were they discussing). You can only choose a code based on this IF more than 50% of the minutes were spent counseling, coordinating care.
I would not bill based on time with just her statement of 10 min, 20 min etc.
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