The limited-time Pre-sale for my Practical Guide to Attending Documentation continues! Get it for 197 $148!

Not your usual billing course. FOR busy doctors, BY a busy doctor. I use short videos (with downloadable resources) walking you through step-by-step so you not only feel 100% confident about billing, but also write notes faster with my unique tips you won’t find anywhere else.

What’s inside? See preview screenshots at the link above.

This is part 3 of 3 about professional billing. If you missed Part 1 and 2, check them out below:

There were updates to time-based billing with the 2023 updates as well. There’s good news and bad news.

Good news: It is now TOTAL time that also includes non-face-to-face time and is much more inclusive.

The bad news: Time requirements have gone up. For example, for initial hospital inpatient or observation charges time requirements have changed from:

30 → 40 minutes for 99221

50 → 55 minutes for 99222

70 → 75 minutes for 99223

and for subsequent hospital inpatient or observation:

15 → 25 minutes for 99231

25 → 35 minutes for 99232

35 → 50 minutes for 99233

Other times for common inpatient charges are as below:

These are threshold times so they must be MET or EXCEEDED (and clearly documented).

So, what is included in TOTAL time?

1. Preparing to see the patient (review of tests)

2. Obtaining and/or reviewing separately obtained history

3. Performing medically appropriately exam / evaluation

4. Counseling, educating patient / family / caregiver

5. Ordering medications, tests or procedures

6. Referring and communicating with other QHP

7. Documenting clinical information in the EHR!

8. Independently interpreting results and communicating results to patient / family / caregiver

Time does not include:

1. Performance of other services that are reported separately

2. Travel

3. Teaching that is GENERAL and not limited to discussion that is required for the management of a specific patient.

Frequently Asked Questions

Can time-based billing be used by ER physicians?

No, ER physicians cannot bill by time. They must use MDM.

Do I have to have an itemized list of the time spent doing each activity?

No, but your note should help explain the medical necessity of that time. This is especially important if billing high-level charges and certainly prolonged care services charges (more below).

Can I use time-based billing always?

This was a question asked to the AMA and the AMA said, “Yes…but we wouldn’t recommend it.” As Sean Weiss (host of “The Compliance Guy” podcast) says, be careful to avoid the medically unbelievable day. For example, your charges should not add up to more than 24 hours. That actually happened and that physician lost their ability to bill Medicare (and likely most other insurances followed suit).

If I mention a time in my note, do I have to bill by it?

No. When you submit a bill, you don’t select “I billed by time” or “I billed by MDM.” If audited, an auditor would review your note and determine if they agree with the level billed. If you mention a time but it didn’t meet the level of your bill, they will then see if your note met the appropriate MDM for that level. With that said, I’d generally avoid mentioning a time unless billing by time to avoid any confusion.

Can I specify a range of time?

No. Pick a time. Don’t use “greater than” language. Use your best guess and pick a single time.

I’m a clinic doctor and review charts the day prior to my clinic. Can I include that time?

No, it must be time on THAT calendar date. (Sorry)

Do I have to include a time in my discharge summary? Don’t they know based on my bill of <30 or >30 minutes?

No. You have to include a time. Again, don’t use “greater than” language. Pick a time. Use your best guess and don’t include the same time over and over again for every patient.

Final tips

• When using split/shared billing (MD + APP), the billing provider must document and perform the “substantive portion” (aka more than half of the total time) of the visit. When both the physician and APP are in the room together, that time can only be counted once (10 minutes total, not 10 + 10 = 20 minutes). By the way, there’s a lot of differences between the AMA and CMS on split / shared billing documentation and attestation requirements. Check out this great resource from codingintel for more info: Split-Shared Services_2024 CPT CMS Comparison (codingintel.com)

• Time must be performed by YOU. Not clinical staff such as nurses.

• No double-dipping: Do not include time that is billed separately such as advanced care planning, critical care, etc.

• The AMA and CMS have different codes for prolonged services. For example, in the picture above instead of 99418 (for the AMA) CMS instead uses G0316. If you use prolonged services often, I’d make sure to talk to your PB department to make sure you are using them correctly and have the appropriate documentation as these will likely be targets for audits by insurances.

That’s all for now. I hope that was helpful.

Please feel free to reach out and ask questions as they help inspire future issues!

Cheers,

Robert

P.S. I had the pleasure of attending the ACDIS (Association of Clinical Documentation Specialists) conference this past week in Indianapolis. I was honored and thankful to meet so many of my subscribers who offered kind words about my newsletter. I hope you post all of those pictures! See you next year!

When you’re ready, there are two ways I can help you:

1. Check out The Practical Guide to Attending Documentation. Available for $148 (a significant PRE-sale discount) but not currently published as I await CME approval. It’s a step-by-step guide using short videos so you can:

• Reduce downgrades (which cost you money) and be 100% confident about billing

• Write shorter, more effective notes

• Prevent lawsuits

• Reduce medical errors

2. Check out The Resident Guide to Clinical Documentation. The course that helps you:

• Prepare for real-world productivity pressures by optimizing your notes for efficiency.

• Gain the confidence to write shorter yet more effective notes.

• Impress your attendings and improve your evaluations.

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