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Prolonged Services: Comparative Differences

Face-to-Face vs. Non-Face-to-Face CPT Codes

Face-to-Face
(CPT Codes 99354-99355, 99356-99357)
Non-Face-to-Face
(CPT Codes 99358-99359)
Have been approved codes for many years Approved for payment on 1/1/2017
Require exclusive F2F time with the patient Does not require any F2F time with the patient
Exclusively add-on codes Independent codes: can be billed alone
Must be billed on the same DOS as the base E&M Can be billed on the same or a different DOS
as the related service
Different code sets for inpatient and outpatient settings Codes apply in both inpatient, outpatient and SNF settings
Only for use with E&M services May be used with E&M and other physician services
Documentation requirements well established Medical records must:
  • support the medical necessity of the service;
  • the time spent; and 
  • the fact that the service was not duplicated
    by other billed services 
    • e.g., E&M services or part of a
      global surgical service
It is not sufficient to say, for example: 
"1 ½ hour of non-face-to-face time spent ____."
Prolonged Services: Comparative Differences of Face-to-Face/Non-Face-to-Face CPT Codes
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