What Time Is It...Time To Get Up To Speed With Time-Based Coding

Have you ever wondered how to capture appropriate levels of evaluation and management when counseling or coordination of care dominates the majority of a visit?  There are some simple tips to remember when billing time-based EM codes.

During the course of an encounter with a patient or caregiver discussions regarding disease processes, risks and benefits of treatment options, or providing the patient with specifics regarding coordinating care with other providers and healthcare entities, may take up the majority of the visit.  This is especially true when a condition or illness has been initially identified, is highly complex, or is not yet under control.  In these circumstances, the standard “key components” may not paint an accurate picture of the appropriate level of service.  History, exam, and medical decision-making are generally the basis for any EM code level; however, there are instances where time may be the deciding factor.  Understanding when to utilize time-based billing is imperative and might be considered time well spent.  In order to support compliant use of time-based billing, provider documentation should clearly identify the below elements. 

  •  Total time of the visit not just time spent counseling
  • More than (>) 50% of the total visit time was dedicated to counseling and coordination of benefits and services
  • Face-to-face with patient (or caregiver), in a professional setting
    • In hospital setting, total time can include both “face-to-face (bedside) time,” and time spent on the floor or unit reviewing results, gathering additional patient information and/or in discussion with other providers
      • Time spent off the unit/floor cannot be captured
      • Time spent attending to other patients cannot be included
      • Time spent discussing the case with students/interns/residents is also excluded
  • A brief summary of counseling and coordination of care including decisions made, risks to the patient associated with treatment versus non-treatment, etc.

Quick Tip #1:   

It would not be appropriate to use time-based statements to support higher levels of EM service when the medical necessity for that discussion is not supported.  Routine overuse of time, rather than the standard key components, could also be a red flag to payers.  It is best to apply this option in a case-by-case basis. 

Quick Tip #2:    

When documenting the total time portion of the “time-based statement” in notes, most CMS MAC’s allow for a generalized attestation, such as “more than 50%” or “> 50%” of total time (yes, you must document the total time of the visit).  Visiting your local MAC website is recommended to ensure exact counseling times are not required, for example: “36 minutes of a 45-minute visit”.

Don’t let time slip away.  When used appropriately, time-based coding can add additional revenue to the bottom line. The following table is a quick guide for typical times associated with common EM codes.  


About the Author                  



Teresa Tate


Teresa Tate, CPC has over 16 years of coding, auditing and provider education experience. As the Director of Professional Fee Coding at HRG, Teresa and the HIM department are constantly coming up with solutions to the unique problems facing pro fee coding.  Teresa, a true educator, is always willing to share her knowledge and experience to forward advancements in coding and the health services industry.   



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