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This information applies to office and outpatient services (99202-99215) performed on or after 1/1/2021.

For information on Time-Based Services prior to 1/1/2021 see topic Time-Based Services Prior to 12/31/2020.

Time-Based Services On or After 1/1/2021

  1. How do counseling and/or coordination of care count toward billing these services based on time?

Answer: As of 1/1/2021, office and outpatient E/M services may be coded based on time whether or not counseling and/or coordination of care have occurred or have dominated the service. Added 1/13/2021

  1. How is total time calculated on the date of the encounter?

Answer: Time includes physician and/or other QHP time, and includes both face-to-face and non face-to-face time spent relative to the patient’s care. Added 1/13/2021

  1. Can clinical staff time be counted in calculating time?

Answer: Time spent separately by clinical staff is not included in calculating time. Added 1/13/2021

  1. When more than one clinician (e.g., physician and QHP) see the patient jointly, how is time calculated?

Answer: When more than one clinician are performing the visit time jointly, time spent is only counted once. Added 1/13/2021

  1. What face-to-face provider activities may be counted in calculating time? 

Answer: Time spent on the same date of service in obtaining and/or reviewing prior history, time spent during a medically necessary examination and time spent in counseling and educating the patient/family/caregiver may all be counted toward total face-to-face time. Added 1/13/2021

  1. What non-face-to-face provider activities may be counted in calculating time?

Answer: Time spent on the same date of service in preparing to see the patient (e.g., reviewing data and records), ordering medications, tests and/or procedures, referring and/or communicating with other health care professionals, documenting clinical information in the medical record, independently interpreting test results (those not reported separately) and communicating that information to the patient/family/caregiver and care coordination may all be counted in calculating time. Added 1/13/2021

  1. Does time need to be spent contiguously or may time on a particular date of service be counted cumulatively?

Answer: Time on a particular date of service, spent on any of the face-to-face or non face-to-face activities defined here, may be counted cumulatively in coding a service. Added 1/13/2021

  1. Question: When level-setting a service based on time in the office or outpatient setting, is time spent alone by a resident added to time spent by the teaching physician with counted in total time spent?

Answer: When level-setting a service based on time, only time spent by an enrolled Medicare provider who is permitted to perform and bill for an E/M service is counted toward total time spent. This limits counted time to time spent by a physician or NPP (PA or NPP). Clinical staff time cannot be counted and, in this context, the resident’s time would be considered as clinical staff time and is not counted. There is an exception to this rule in the PCE setting, described in the next FAQs below. Added 2/3/2021

  1. Question: When level-setting a service based on time in a Primary Care Exception outpatient setting, is time spent alone by a resident added to time spent by the teaching physician counted in total time spent?

    Answer: In a PCE setting, a teaching physician supervises up to four qualified residents and must remain available to the residents throughout the clinic session to see a patient personally at a resident’s request. Residents are permitted to see patients without the direct personal presence of the teaching physician and must review the plan of care for each patient with the teaching physician before the close of the clinic session. In the PCE setting only, total time for level-setting a visit includes the teaching physician’s time (in seeing the patient and/or reviewing the plan of care) and the resident’s time during his/her F2F encounter with the patient. Added 2/3/2021

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Time-Based Services On or After 1/1/2021
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