CPT 2011 Asks for CMS re-Examination of Time as Averages or Thresholds

CPT 2011: The doctor must have spent a time closest to the chosen code, according to CPT Assistant

All that fine green print on time in your E/M CPT 2011 manual comes down to one thing: you can round to the closest time code. However, that advice from CPT contradicts Medicare's threshold time guideline.

CPT treats times as averages

CPT 2011 indicates that you can use the code closest to the documented time. That piece of advice is nothing new. In choosing time, the doctor must have spent a time closest to the chosen code, according to CPT Assistant, Aug. 2004.

Your documented time must be equal to or cross the average time given to bill that level. For a 35-minutes spent on a medically necessary counseling-dominated visit is a 99214, according to CPT you could report 99215.

Medicare has considered times thresholds

Medicare has always considered the times indicated in CPT's code descriptors to represent minimums. The doctor would choose the lower code (for example 99214… physicians typically spend 25 minutes face-to-face with the patient and/or family …) unless the time was greater or equal to the higher-level code's required time (such as 40 minutes for 99215).

Will Medicare alter its position?

When questioned on whether Medicare would change the allotments from thresholds to averages at the CPT® and RBRVS 2011 Annual Symposium, medical directors were hesitant to give a definitive answer. "I do not want to say one way either 'yes' or 'no' at this juncture," said E/M expert Deborah Patterson, MD, clinical medical director for Trailblazer Health Enterprises, LLC in Dallas.

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