The description for these codes in CPT state: "Prlonged evaluation and Management service before and/or after direct (face-to-face) patient care ..." (emphasis added by FTB).
So, by definition, you cannot use these codes in your scenario ... when ONLY record review was performed.
If the physician had reviewed these records on the same day as an office visit, he would document as part of his office visit note something about "extensive review of records, (describe what was looked at and findings), requiring X minutes" (has to be at least 30 minutes).
NOTE: non-face-to-face codes are typically never paid.
F Tessa Bartels, CPC, CPC-E/M
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