Coding Clinic: Hospital Follow Up Visits Based On Time

In my coding clinic series, I previously explained all the complicated rules necessary to pass an audit by the chart police. You can find how to pass an audit for a 99231, 99232, and 99233. Did you know that you can bill these codes based on time alone?  One astute reader asked if it was possible to bill these hospital follow up codes based on time only. The answer is yes and no. You can use time, but you must also document other strict rules. Before I explain the rules read this:

Nothing I say here means Jack. I am not a licensed coding compliance officer. Even if I was, what I say doesn't matter since I'm not the one paying your bills. The Medicare National Bank owns your paycheck, so you have to do what they say. It doesn't matter if I'm right or not. My interpretations are based on my understanding of the Evaluation and Management Guidelines of 1995 and 1997. As of November 2005, until further notice, carriers have been directed to use these guidelines in their reviews. If you disagree with my statements, you will be tarred and feathered. .

So here goes: In order to bill hospital follow up codes based on time you must document all three of the following circumstances:

1. Does the documentation reveal the total time? (Face-to-face in outpatient setting or floor time in inpatient setting)
2. Does the documentation describe the content of counseling and or coordinating care?
3. Does documentation reveal that more than half of the time was spent counseling or coordinating care?

If you answer yes to all three of these questions, you don't have to document jack about vital signs and review of systems and HPI and physical exam and adding up points and looking up charts and risk tables. You don't have to do any of that. You just need to document these three facts. Sounds great right? Right? Do you remember the time factor the AMA thinks that each level of care should take? 15 minutes for a 99231, 25 minutes for a 99232, 35 minutes for a 99233. As I understand the rules, those are your parameters for choosing your level of billing based on time. And because time is so devalued in E&M coding, due to the RVU/RUC/SGR disaster, every clinic in America would go bankrupt if they only billed E&M codes based on these time parameters. 

It's a rare day in Hell that I would ever use this "out" for the complex rules, because rarely do I spend 1/2 the time counseling. But if do, and time slips away from me and I find myself in a family meeting for 30 minutes, or explaining to a drug addict with dependent personality traits why they aren't going to get any more morphine from me, you can be dang sure I'm using this as an out and telling my calculator to take a hike. 
For threshold times for all hospital admission, consult and followup visits (the time the AMA expects each visit to take) go read about it at my prolonged service codes clinic.

You can see much more here in my coding lectures or earn CME at E&M University.