Tick-Tock: Understand Why Time Matters for E/M Coding

understand time for E/M coding success

For E/M, there has been a lot of attention on how the role of time will change in 2021. But what about right now? After this skill sharpener on time in the AMA CPT® E/M guidelines, you’ll have a better understanding of time’s current role in E/M coding.

Where to Find AMA CPT® E/M Guidelines

The CPT® code set includes a set of E/M Services Guidelines that give you important information about applying the codes in the E/M section. If you’ve got a paper CPT® manual, the guidelines are most likely located just before the first E/M code. If you use TCI SuperCoder online code search, the guidelines are linked on your code’s page in the CPT® Guidelines section or in the left-side Coding Tools menu under Coding/CPT®/Guidelines.

Important: Factor in your payer guidelines, as well. There may be information that differs from the official AMA CPT® guidelines.

Fit Time Into the Bigger E/M Picture for Clearer Coding

The time typically required to provide an E/M service is included as part of the basic format of most E/M code descriptors. Time is one of the seven components used to define the E/M level service. These are the other components:

Key components



Medical decision making

Contributory factors


Coordination of care

Nature of presenting problem.

Understand Why Time Counts for E/M Services

Did you know time became an “explicit factor” for E/M in 1992? Just look at the fun information you can learn if you read the CPT® guidelines!

An example of time in an E/M code descriptor is this phrase at the end of the descriptor for office/outpatient visit code 99213: “Typically, 15 minutes are spent face-to-face with the patient and/or family.”

That word “typically” is important. The guidelines explain that the times shown are averages representing a range of times possible for the given level.

Where you won’t find time: Emergency department (ED) E/M codes steer clear of times because of the nature of moving from patient to patient in the ED setting.

But why use time at all? Work is hard to quantify, and intraservice time offers a somewhat objective way to determine the level of work, state the AMA CPT® guidelines, citing physician surveys that collected data on time and work involved in typical E/M services.

The AMA landed on using intraservice time because it’s simpler to measure than total time and the surveys showed a strong relationship between intraservice and total time. But “simpler” is relative because we’re not done digging into what intraservice time means.

Base Intraservice Definition on Service Location

Intraservice time for office and other outpatient visits is face-to-face time. For hospital and other inpatient visits, intraservice time is unit or floor time. The reasoning is that is where the bulk of work happens for each respective service.

Office/outpatient: The AMA defines face-to-face time for office/outpatient E/M codes as time face-to-face with the patient and/or family. Getting the history, performing the exam, and counseling the patient are all included.

Hospital/inpatient: Unit or floor time is the standard for hospital observation, inpatient hospital services, initial inpatient hospital consultations, and nursing facility services, according to the guidelines. To find the unit or floor time, look at the time the provider is present at the patient’s bedside AND on the unit/floor performing services for the patient. Creating or reviewing the chart, performing the exam, writing notes, and communicating with the family and other professionals all count toward the time, the guidelines state. But be careful. If the provider is not on the unit/floor, it doesn’t count, even if she’s reviewing pathology or radiology findings for the patient in another part of the hospital.

For both intraservice time definitions, the guidelines acknowledge that providers spend time outside of the face-to-face time on visit-related work, but add the reminder that studies show that intraservice time correlates to total time.

When Does Time Matter for E/M?

Currently, it is possible that you select most of your E/M codes based on the code’s required combination of history, exam, and medical decision making (and of course medical necessity). But the guidelines include the rule that “When counseling and/or coordination of care dominates (more than 50%) the encounter with the patient and/or family (face-to-face time in the office or other outpatient setting or floor/unit time in the hospital or nursing facility), then time shall be considered the key or controlling factor to qualify for a particular level of E/M services.” This rule includes time with foster parents, legal guardians, and other non-family members responsible for patient care or decision making.

The guidance given on documentation requirements is not long: “The extent of counseling and/or coordination of care must be documented in the medical record.” Check payer requirements to see if there’s a preference for documenting start and stop times or tallying the total time, but be sure you can support that more than 50 percent of the encounter centered on counseling or coordination of care.

Explore These Final Tips to Advance Your Knowledge

EHR: If your EHR tracks total time, providers and coders need to understand exactly what it’s tracking and whether you can apply that information to coding. To code based on time, you need to know the total time and the time spent on counseling and/or coordination of care to see if you met the more-than-50-percent requirement.

Topic: Along with the time involved, documentation of the topic of the counseling and/or coordination of care will help support your coding, such as “25-minute office visit with 20 minutes spent on counseling about medication options for recurrent bronchitis.”

Prolonged services: The CPT® code set includes codes for prolonged E/M services. Be sure to acquaint yourself with the rules for +99354-99360 and +99415-+99416 to understand how to report services that extend beyond the typical time listed for the E/M code.

What About You?

Do you code E/M based on time often? Do you expect to code based on time more once the E/M changes go through?


Deborah works on a wide range of TCI SuperCoder projects, researching and writing about coding, as well as assisting with data updates and tool development for our online coding solutions. Since joining TCI in 2004, she’s covered the ins and outs of coding for radiology, cardiology, oncology and hematology, orthopedics, audiology, and more.

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