“Spotlight on CPT” will be covering changes to the Evaluation and Management (E&M) section of CPT that address the concept of “time” for 2024. There has been a note addition to the Guidelines for Selecting Level of Service Based on Time in the E&M Services Guidelines as well as changes to the codes for both new and established office or other outpatient services.
First, let us look at the guideline for using time to determine the E&M service level. Here is a review of guidelines for time that haven’t changed:
1. E&M codes for the emergency department are NOT based on time due to the variable nature of the encounters.
2. Some categories have specific time requirements such as Critical Care Services. Apply those concepts as outlined when coding from those sections.
3. In order to use time, the provider or other qualified health care professional (QHCP) must have a face-to-face with the patient and/or family/caregiver.
4. When coding for office or other outpatient services, if the provider’s or QHCP’s time is in supervision of clinical staff who perform the face-to-face component of the encounter, then code 99211 should be selected.
5. When determining code selection:
a. Time is total time on encounter date
b. Include both face-to-face and non-face-to-face time
c. Do not include time of clinical staff
d. Time is not location dependent (office, hospital unit)
e. Time spent on separately reportable services should not be included
Now, let’s turn our attention to the changes added to “time” assignment for 2024. The first big change is that when a service can be billed based on time, there is now a required amount of time that must be met. Previously, CPT allowed the use of a midpoint, meaning if the time requirement for a service was fifteen minutes, if the provider spent 8 minutes or more, they could assign the code since they spent more than half the required time on the service. Now, they must meet or exceed the threshold in order to use time.
This concept is seen with revisions to the office or other outpatient services code 99202-99215. Each code in this range now states: “When using total time on the date of the encounter for code selection, __minutes must be met or exceeded”.
Office or other outpatient visit – New patient
Office or other outpatient visit – Established patient
99212 – 10 minutes must be met or exceeded
99213 – 20 minutes must be met or exceeded
99214 – 30 minutes must be met or exceeded
99215 – 40 minutes must be met or exceeded
Notice that the number of minutes that is required is less for an established patient than for a new patient as would be fitting.
Another addition to the time section is that when determining total time, it is appropriate to add the time spent by both the provider and the QHCP who each do a part of the face-to-face and non-face-to-face work in order to determine the total time. This only applies when both providers have separate time with the patient, the family, or the caregiver. If both the provider and the QHCP see the patient at the same time (for instance, 15 minutes), you may only use 15 minutes of total time, not 30.
Now, light has been shed on changes to E&M coding of time.
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About the Author
Dianna Foley, RHIA, CHPS, CCS, CDIP, is an HIM professional with over 25 years of experience. She earned her bachelor’s degree from the University of Cincinnati and holds RHIA, CHPS, CDIP, and CCS certifications from AHIMA, along with being an AHIMA-approved ICD-10-CM/PCS trainer. Dianna has held many positions in HIM and is now an independent coding consultant. She previously served as the program director for Medical Coding and HIT at Eastern Gateway Community College. Dianna is an AHIMA-published author and has volunteered with AHIMA on projects including certification item writing, certification exam development, coding rapid design, and most recently has served on AHIMA’s nominating committee. She is a presenter on coding topics at the national, state, and regional levels and serves as OHIMA’s Education Coordinator. Dianna mentors new AHIMA members and also provides monthly educational lectures to coders and clinical documentation specialists.
