Navigating E/M Reporting: Time-Based Billing and Separately Reported Services

March 29, 2024 | By: Teresa Schrage, RDCS, RVT, CPC, CPMA

Reporting an E/M with separately reported services continues to be a topic of discussion amongst coders, auditors, and providers. First, let’s review what a significant, separately reported E/M is and what identifies the service. An E/M is significant and separately identifiable from a procedure/service if the work related to the E/M can be separated from the work related to the procedure/service and there is no overlap between the two. CPT® modifier 25 identifies the service as significant and separate. But what about when a provider chooses to bill based on time to support the level of service in lieu of the medical decision-making components with separately reported services?

Before 2021, a provider could report the E/M service based on time, with the provider being face-to-face with the patient, and more than fifty percent of the total time was spent on counseling or coordinating treatment with the patient. The documentation guidelines now state that the provider can report the E/M based on time, including face-to-face and non-face-to-face time. The only condition is that the time counted must be spent on the day of the encounter.

Activities that can be counted on the day of the encounter include:

• Preparing to see the patient (e.g., review of tests)
• Obtaining and/or reviewing separately obtained history
• Performing a medically appropriate examination and/or evaluation
• Counseling and educating the patient/family/caregiver
• Ordering medications, tests, or procedures
• Referring and communicating with other healthcare professionals (when not separately reported)
• Documenting clinical information in the health record
• Independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver
• Care coordination (not separately reported)

There were also time ranges to support each level of service. As of January 1, 2024, CPT revised the guidelines to remove the time ranges from the new and established office/outpatient E/M codes and replace them with a single total time amount, the lowest number of minutes in the current range for each code. Time “must be met or exceeded” according to the new wording in each code’s descriptor.

So now that we have distinguished between the separately billable service and time-based billing let’s put them together. The same rules apply if a provider chooses the time to support the E/M and reports a separately reported service. Modifier 25 would be amended to the E/M code that supports the total time documented by the provider. Just remember the time spent on the separately reported service cannot be counted toward the time of the work of the problem assessment because time spent performing a service cannot be counted twice. I recommend that my providers document a statement like “I spent XX minutes total time today in patient care, not including any separately billed procedures” within the encounter note.

Whether a provider chooses to bill based on time or Medical Decision-Making components with a separately reported service, the goal is to educate them on how to get compensated for their work, and more importantly, the documentation supports the level of service with a separately reported service. It may seem easier to bill based on time, but remember, we want to caution our providers on the impossible day.  The impossible day is when more time is documented than the total time of their schedule. Time-based billing is an option, but we should educate our providers on it. Even though it is an option, let it be the exception and not the rule!

Teresa Schrage, CPC, CPMA

References: Current Procedural Terminology 2024 Professional Edition. AMA, 2024.