You know, most of the training I see out there, and even most of the training that I’m asked to do on E&M 2021 documentation guidelines surrounds MDM, so a lot of it isn’t even on time-based. So, set your watch. Let’s spend just a few minutes talking about…time.
I’d like to start off by going to 2021 documentation guidelines and for just a moment, let’s not go to the standard documentation guidelines. Let’s look at the March 2021 Technical Corrections version. (By the way, I always recommend you keep around both editions -and actually, in our teaching manuals, whether you come to our Workshop or our E&M BootCamp® or the CPMA, BootCamp®, we give you both copies in our manuals, and we do that because both are very useful.)
So, in the technical corrections version, they added some “do not’s” around reporting time. The first “do not” is:
“Do not count time on the following; the performance of other services that are reported separately”.
This caveat had to be added through those technical corrections to make sure that we had the guidance that if there is another reportable CPT code, we understood that there couldn’t be a double count of time, especially if we were being reimbursed for time for that CPT code and/or simply the work of the CPT code in conjunction of these service for the time in the E&M encounter. That would be our famous words “double-dipping.” You said that with me didn’t you. 😊 Again, we had to ensure that that does not occur – so, we have to have what we refer to as a “carve-out” statement. Now, I know from teaching a lot of workshops, that there are some people who don’t feel like carve-out statements are required. I’m going to tell you that carve-out statements are emphatically required! This is actually a good time that a macro statement, provided it’s updated, could be of key benefit to your providers. Start off a macro statement for your provider that says “my total time on the date of this encounter included only my time with the patient without diagnostic time or procedural based services and included XX minutes”. That way, our provider is, (1) reminded when they go to document time, they need to subtract out the time that included. And (2) we now have our documentation statement that is going to include that carve-out statement right away. When I see a time-based E&M but I also see that an EKG was performed, or I see a chest X-ray was performed, how do I know that the total time of that E&M is not inclusive of those ancillary services that were also performed unless that provider tells me that those ancillary service times are not included in that E&M time? That carve-out statement has to be there. The second is kind of assumed, but there is a reason that it’s in here:
“Do not count time spent on travel”.
So, if the provider is going to see the patient in the home, or maybe going into the hospital at night…(whoops, that would be inpatient, not counted!). So, travel. Don’t count travel, okay? We’ll just leave it right there.
Finally, we have “Do not count time spent”. Now, this one didn’t slap me in the face until I re-read it.
“Do not count teaching that is general and not limited to discussion that is required for the management of a specific patient”.
Now that’s kind of a gray statement. So, what exactly…what specifically does this statement warn us against counting in that total time? “Teaching that is general and not limited to discussion that is required for the management of the patient.” So, if the patient is here today and being treated for a specific problem, but then the provider gives obesity training to this patient or they start educating them on diet and exercise, is that something that maybe should be considered as a warning flag to the auditor? Remember, I’ve kind of pushed these codes recently – the preventive counseling add-on codes. These are time-based codes that the provider can bill (if you need these codes, drop me an email). Those codes would be much more fitting for those scenarios than just billing these visits on time. That is exactly what the 2021 documentation guidelines are warning about here. They’re saying “whoa, time out! You can’t just randomly start educating this patient on something just to get your time-based billing up.” So be cognizant when you’re reading time-based billing. We need to make sure that (A) we have carve-out statements for time; (B) Nobody is billing for travel; and (C) that we don’t have erroneous education that is not related to the problems addressed during today’s encounter that are being added to the total time of the encounter. If that’s the case, then our providers should be looking at an add-on code separate from today’s encounter to report those different services.
So, I hope this was helpful and I hope I didn’t take too much time out of your day!
