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Are Physicians Required to Document Time Spent on Each Task Associated With an Outpatient Visit?

Learning Objectives
1. Describe the myth or issue that impacts physicians and their care teams
2. Explain how the 2021 revisions to the E/M office visit coding documentation requirements impact how physicians should bill office/outpatient E/M encounters
0.25 Credit CME
Abstract

With the 2021 revisions to the E/M office visit coding documentation requirements, there exists conflicting information regarding how physicians and other qualified health professionals are required to document the time spent on each specific task associated with an outpatient visit due to how these revisions are a significant departure from the prior 1995 and 1997 rules.

The Myth

Physicians and other qualified health professionals are required to document the time spent on each specific task associated with an outpatient visit.

Debunking the Myth

In a significant departure from the 1995 and 1997 rules, the 2021 revisions to the E/M office visit coding documentation requirements no longer include the documented history and physical exam in determining the appropriate level of service. Physicians now have the choice to bill office/outpatient E/M encounters solely based on medical decision making (MDM) or the total time spent on the date of that encounter. The time spent on the encounter includes both face-to-face and non-face-to-face time personally spent by the physician (and/or other qualified health care professional) and may include several activities (see list below).

Documenting and coding based on MDM

When documenting and selecting a code based on MDM, consider that MDM includes establishing diagnoses, assessing the status of a condition, and/or selecting a management option. MDM in the office or other outpatient service codes are defined by three elements:1 [AMA Coding Changes Guide (PDF)]

  • The number and complexity of problem(s) that are addressed during the encounter.

  • The amount and/or complexity of data to be reviewed and analyzed.

  • The risk of complications and/or morbidity or mortality of patient management decisions made at the visit, associated with the patient's problem(s), the diagnostic procedure(s), treatment(s).

Documenting and coding based on time

If time is to be used to calculate the E/M code rather than MDM, physicians should include the total amount of time they spent associated with that visit on the date of service in determining which code to use. Besides face-to-face time in the exam room or in a telehealth encounter, this also includes prep time and follow-up work on that same date. The CPT® Evaluation and Management Code and Guideline Changes provide durations of time for billing based on time for a variety of E/M services. Times associated with office or other outpatient services are expressed in discrete, non-overlapping ranges within the code descriptors.1

CPT code and time range

99202: 15-29 mins

99203: 30-44 mins

99204: 45-59 mins

99205: 60-74 mins

99211: N/A

99212: 10-19 mins

99213: 20-29 mins

99214: 30-39 mins

99215: 40-54 mins

Important notes

  • There is no requirement to document the total time spent if the physician is not using time to calculate the level of service.

  • If using MDM for the level of service, there is no requirement to spend the correlating amount of time on the encounter.

Physician/other qualified health professional time includes the following activities (when performed):2

  • Preparing to see the patient (eg, review of tests)

  • Obtaining and/or reviewing separately obtained history

  • Performing a medically necessary and appropriate examination and/or evaluation

  • Counseling and educating the patient/family/caregiver

  • Ordering medications, tests or procedures

  • Referring and communicating with other health care professionals (when not reported separately)

  • Documenting clinical information in the electronic or other health record

  • Independently interpreting results (not reported separately) and communicating results to the patient/family/caregiver

  • Care coordination (not reported separately)

Do not count time spent on the following:

  • The performance of other services that are reported separately

  • Travel

  • Teaching that is general and not limited to discussion that is required for the management of a specific patient

Resources

January 2022 MLN Booklet: Evaluation and Management Services Guide. Accessed May 3, 2022.

Nordic-AMA 2021 E/M Updates: What Will Happen to the Physician Note? Accessed May 3, 2022.

AMA CPT® Evaluation and Management Office or Other Outpatient and Prolonged Services Code and Guideline Changes. Accessed May 3, 2022.

AAFP Tips For Using Total Time to Code E/M Office Visits in 2021. Accessed May 3, 2022.

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The AMA Debunking Medical Practice Regulatory Myths series provides physicians and their care teams with regulatory clarification to streamline clinical workflow processes and improve patient outcomes. Learn more

Successful completion of this CME activity, which includes participation in the evaluation component, enables the participant to earn up to:

0.25 Medical Knowledge MOC points in the American Board of Internal Medicine's (ABIM) Maintenance of Certification (MOC) program;

0.25 Self-Assessment points in the American Board of Otolaryngology – Head and Neck Surgery’s (ABOHNS) Continuing Certification program;

0.25 MOC points in the American Board of Pediatrics’ (ABP) Maintenance of Certification (MOC) program;

0.25 Lifelong Learning points in the American Board of Pathology’s (ABPath) Continuing Certification program; and

0.25 CME points in the American Board of Surgery’s (ABS) Continuing Certification program.

It is the CME activity provider's responsibility to submit participant completion information to ACCME for the purpose of granting MOC credit.

Article Information

AMA CME Accreditation Information

Credit Designation Statement: The American Medical Association designates this enduring material activity for a maximum of 0.25 AMA PRA Category 1 Credit(s)™. Physicians should claim only the credit commensurate with the extent of their participation in the activity.

CME Disclosure Statement: Unless noted, all individuals in control of content reported no relevant financial relationships.

If applicable, all relevant financial relationships have been mitigated.

References:
1.
American Medical Association.  CPT® Evaluation and Management (E/M) Office or Other Outpatient and Prolonged Services Code and Guideline Changes; 2021.  Accessed May 3, 2022. https://www.ama-assn.org/system/files/2019-06/cpt-office-prolonged-svs-code-changes.pdf
2.
Joseph  C, Levy  B.  2021 E/M Updates: What Will Happen to the Physician Note. Nordic-American Medical Association; 2021.  Accessed May 3, 2022. https://www.ama-assn.org/system/files/2021-03/ama-em-updates-physician-note-white-paper.pdf
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