Editor’s note: Kimberly Hoy, Esq., director of Medicare and compliance for HCPro, Inc., is the author of this week’s note from the instructor.
This week I thought I’d take the opportunity to address a confusing coding issue related to new guidance added to the CPT Manual this year for reporting time. CPT added an entire new paragraph to the introduction section on properly reporting time-based codes.
Some of the new guidance reiterates standards that have been in the Medicare guidelines or coding rules for some time. For instance, you must reach the mid-point of a unit of time to code for that unit of time (e.g., 31 minutes to code for one hour). They also mention that when time-based services are provided concurrently with other services, the time associated with concurrent services should not be used in the overall time reported for the time-based service. This seems to be a restatement of a rule providers have struggled with for a couple of years now related to subtracting time for services with “active monitoring” from the overall time a patient is in observation.
But, although most of the instructions reiterate or agree with current CMS policy, there is one glaring exception.