“With the loss of CPT 99343, is time a justification for the use of CPT 99344? My initial home visits (and now assisted and congregate living facilities) easily meet or exceed sixty minutes. Before I see patients, they completed a five page demographics that includes two pages of review of systems. I also have the chart notes from the referring physician and/or the CMS-485 from a home care agency (or the input paperwork from the hospice agency) that is all reviewed while face to face with the patient. The physical exam is quite time consuming in and of itself followed by assessment, treatment, plan of care and coordination of care. It seems that everything I can read says that I am justified in billing CPT 99344 using time. Thoughts?”
As of January 1, 2023, when it comes to E/M codes for home or residence services, the following changes have been put into effect:
Deletion of Home or Residence Services E/M code CPT 99343.
Revision of Home or Residence Services E/M codes CPT 99341, CPT 99342, CPT 99344, CPT 99345, CPT 99347-CPT 99350, and guidelines.
The following codes are used to report evaluation and management services provided in a home or residence. Home may be defined as a private residence, temporary lodging, or short-term accommodation (eg, hotel, campground, hostel, or cruise ship). These codes are also used when the residence is an assisted living facility, group home (that is not licensed as an intermediate care facility for individuals with intellectual disabilities), custodial care facility, or residential substance abuse treatment facility.
Here are the codes:
CPT 99341 Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straight forward medical decision making. When using total time on the date of the encounter for code selection, 15 minutes must be met or exceeded.
CPT 99342 Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded.
(CPT 99343 has been deleted. To report, see CPT 99341, CPT 99342, CPT 99344, CPT 99345)
CPT 99344 Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and moderate level of medical decision making. When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded.
CPT 99345 Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using total time on the date of the encounter for code selection, 75 minutes must be met or exceeded. (For services 90 minutes or longer, see prolonged services code CPT 99417)
CPT 99347 Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and straightforward medical decision making. When using total time on the date of the encounter for code selection, 20 minutes must be met or exceeded.
CPT 99348 Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded.
CPT 99349 Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and moderate level of medical decision making. When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded.
CPT 99350 Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded.
(For services 75 minutes or longer, see prolonged services code CPT 99417)
Guidelines For Selecting Level of E/M Service Based on Time:
For coding purposes, time for these services is the total time on the date of the encounter.
It includes both the face-to-face time with the patient and/or family/caregiver and non-face-to-face time personally spent by the physician and/or other qualified health care professional(s) on the day of the encounter (includes time in activities that require the physician or other qualified health care professional and does not include time in activities normally performed by clinical staff) It includes time regardless of the location of the physician or other qualified health care professional (eg, whether on or off the inpatient unit or in or out of the outpatient office). It does not include any time spent in the performance of other separately reported service(s). Physician or other qualified health care professional time includes the following activities, when performed:
-preparing to see the patient (eg, 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 health care professionals (when not separately reported)
-documenting clinical information in the electronic or other health record
-independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver.
-care coordination (not separately reported)
Do not count time spent on the following:
1. The performance of other services that are reported separately
2. Travel
The total time that was dedicated to the performance of the E/M service must be broken down into the exact amount of time that was performed for every phase of the total time that was utilized in order to appropriately document the required time for the E/M service that was billed. For E/M Code CPT 99344, 60 minutes of total time must be spent performing the E/M service and documented as such. Every minute needs to be attached to a specific part of the total time.
This is my opinion.
Michael G. Warshaw, DPM, CPC
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