8 visits based strictly on time are meeting level 5 plus an additional 12 patients are being seen. Exactly how many hours is this provider working a day?

I have no problem coding based on time and billing what is supported. I am not clinical and if I felt something was out of line on the medical necessity piece I would refer that back to the medical director to handle, I totally agree that is not my job to figure out and is way outside my scope of practice.

What is not outside my scope of practice however is making sure we aren't billing for more time than is physically possible to work. This is something the OIG looks at quite a bit. So I agree this type of coding could put you at higher risk for audit. If it is all legit, no worries, let them audit. If it any part is questionable, then you need to work with whoever is involved to fix the problem one way or the other.

Good luck,