Addition of subsequent observation care codes 99224-99226 by CPT® 2011 left many coders perplexed. These new codes featured typical times associated, even though the initial observation care codes 99218-99220 don’t have typical times.
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CPT® 2012 manual, which takes effect on Jan. 1, will remedy that problem, with the addition of the following typical time guidelines:
- 99218 — …Physicians typically spend 30 minutes at the bedside and on the patient’s hospital floor or unit
- 99219 — …Physicians typically spend 50 minutes at the bedside and on the patient’s hospital floor or unit
- 99220 — …Physicians typically spend 70 minutes at the bedside and on the patient’s hospital floor or unit
The exact reasons for the CPT® committee’s inclusion of these codes won’t be clear until the AMA’s November CPT® Symposium, but it seems that the addition of typical times could open the door for coding based on time.
“There are only two ways that you can use time as a basis for selecting an E/M code,” says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a consulting firm in Tinton Falls, N.J. “If counseling/coordination of care takes up 50 percent or more of the visit, and if the code has a typical time associated with it. So by these codes now having a time reference, it sounds like we may have a way to reference time used if counseling or coordination of care takes up at least 50 percent of a visit. In addition, this could open the door to collecting for prolonged service times if the time the doctor spends exceeds 30 minutes more than the allotted time, and the visit notes are documented as such,” Cobuzzi adds....
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