I was faced with this dilema last week and found good info. in my CPT-Assistant E/M section.
Out of the 31 minutes, was more than 50% spent on counseling? Yes (16min)
As long as the provider writes total time spent, how much of that was spent on counseling/coordination of care (more than 50%), and an explanation of the care/counseling, then he or she may bill based on time..
In your case it would be a 99214 not the 99213, if all of the above criteria is met.
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