Time-based E/M Services: Exceptions That Might Surprise You

“Time is on my side. Yes it is.” But knowing whether or not time is a factor to qualify for a particular level of E/M can lead to uncertainty. So when is time a factor?

Providers can assign an E/M level based on time rather than on the elements of the history, examination, and medical decision making when counseling and/or coordination of care dominates the physician-patient and/or family encounter.

For accurate coding, it’s crucial to understand the required documentation and the many exceptions.

Download our free eBrief, "Clear Up The Confusion Around Time-Based E/M Services," for a deeper dive into this topic.

Time Exceptions

Extensive time spent performing the key components of history, exam, and medical decision making due to factors such as language barriers cannot be coded based on time.

In the outpatient setting, only face-to-face time with the patient or family can be counted. In the inpatient and nursing home settings, time can be counted using face-to-face time with the patient as well as time spent on the unit or floor, but the time must be related directly to the patient’s care.

Refer to the CPT® manual for the total encounter times associated with each E/M level.

Inpatient Discharge Codes

There are two hospital discharge day management codes:

99238 – Hospital discharge day management: 30 minutes or less

99239 – Hospital discharge day management: more than 30 minutes.

Providers should report one discharge code per hospitalization. The documentation for these codes should include, as appropriate:

• Final examination of the patient
• Discussion of the hospital stay, even if the time spent by the physician on that date is not continuous
• Instructions for continuing care to all relevant caregivers
• Preparation of discharge records, prescriptions, and referral forms

While both codes are time-based, not all MAC carriers require documentation of time for 99238. It is imperative, however, to document the time for 99239. Without the documentation of time for 99239, the service might be reduced to 99238 or denied entirely.

Check with your local MAC on the documentation of time requirements for 99238.

Download our free eBrief, Clear Up The Confusion Around Time-Based E/M Services, to learn more about the documentation requirements for some of the most common E/M services associated with time, such as counseling and coordination of care, critical care services, smoking cessation and much, much, more.