Chiropractic E/M Coding Guide Part 3: Coding Using Time
In this third part of our E/M coding series, we focus on one of the biggest changes introduced in the 2021 evaluation and management (E/M) guideline updates: selecting codes based on time. While time-based coding offers a simpler approach to selecting the appropriate E/M level, chiropractors must understand what time counts, which activities are excluded, and how to properly document time spent during a patient encounter.
The 2021 E/M coding updates gave providers the option to select office/outpatient E/M codes based on either total time or medical decision-making (MDM). Unlike the previous guidelines, where time was used only in specific circumstances, time can now serve as the sole factor for code selection when documentation supports the required threshold. Proper understanding and documentation of time can help chiropractors improve coding accuracy, support medical necessity, and reduce audit risk.
Per the 2021 evaluation and management (E/M) guideline changes, codes may be selected based on time alone. This is a big departure from how time was used in the past, as an infrequent option. In many ways, it provides a straightforward way for providers to select the correct code, but it also comes with several considerations.
E/M Code Selection Based on Time
The “total time” used for code selection is based on face-to-face time and non-face-to-face time personally spent by the clinician on the day of the encounter. It does not include time spent on activities normally performed by clinical staff, or on separately reportable services, and it doesn’t matter where the clinician is when doing the non-face-to-face work. It also would not include time spent shooting the breeze with the patient about their family or last night’s football game.
There are eight office/outpatient E/M codes that have time thresholds (99211 does not have a time element, and in fact, does not even require the presence of a physician). The time thresholds are as follows:
| CPT Code |
Total Time (must be met or exceeded) |
|---|---|
| 99202 | 15 minutes |
| 99203 | 30 minutes |
| 99204 | 45 minutes |
| 99205 | 60 minutes |
| 99212 | 10 minutes |
| 99213 | 20 minutes |
| 99214 | 30 minutes |
| 99215 | 40 minutes |
What Counts Toward E/M Time?
The official guidelines offer a list of things that might be appropriate to count towards this time. They include:
Preparing to see the patient (eg, review of tests)
Reviewing the separately obtained history
Performing an evaluation
Educating the patient or family
Ordering tests
Communicating with other clinicians
Documenting clinical information in the record
Independently interpreting results and communicating them to the patient or family
Care coordination
The instructions tell us that we are not to count time spent on the following:
The performance of other services that are reported separately
Travel
Teaching that is general and not specific to a patient
Documenting Time for Chiropractic E/M Coding
There is no guidance on what verbiage should be used to document time, but it would be wise to consider listing a few of the items from above, verbatim, to support how the time was spent and to support medical necessity. Specifying start and stop times would make the record even stronger, especially when the time is non-contiguous. For example, a provider could count the time spent scoring an outcome assessment and composing a care plan, even if it is a few hours after the patient left. It just needs to be the same calendar day.
Sample documentation of time for a 99213 might look like this:
“Physician spent 24 minutes of total time (not including separately billed procedures), from 11:24AM to 11:48AM, performing a medically appropriate examination, educating the patient, and documenting clinical information in the electronic record.”
*Please note that there are no specific documentation requirements for time, but this kind of verbiage would make the documentation very defensible if challenged by a third party.
When the Time Method May Not Be the Best Option
The time method seems simple, but there are instances when it may not be the best option. For example, what if a new patient exam only takes 13 minutes? According to the time guidelines, that exam would not be billable. That’s where Medical Decision Making (MDM) can come into play. Stay tuned for Part 4 of this blog series for a deep dive into MDM.
FAQs
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Beginning in 2021, providers can select office/outpatient E/M codes based on total time spent on the date of the encounter rather than relying on the history, examination, and medical decision-making requirements.
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Total time may include activities such as preparing to see the patient, reviewing the history, performing an evaluation, educating the patient, ordering tests, documenting clinical information, interpreting results, and coordinating care.
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Time spent on separately reported services, travel, and general teaching that is not specific to a patient cannot be included in total E/M time.
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No specific documentation requirements exist for time, but including start and stop times and listing activities performed can make documentation more defensible if challenged.
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No. The total time must meet or exceed the threshold for the selected E/M code. If the time requirement is not met, providers may need to consider selecting the code based on medical decision-making instead.
Conclusion
Selecting E/M codes based on time can provide a straightforward approach to chiropractic coding, but proper documentation remains essential. Chiropractors should understand what time can be counted, what activities are excluded, and how to clearly document time spent to support medical necessity and defend against potential audits.
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This is Part 3 of a 4-part E/M Coding Mastery Series. Stay tuned for the final part to be released.
Part 1: Chiropractic E/M Coding Guide Part 1: New vs. Established Patients (99201–99215 Explained)
Part 3: Coding Using Time
Part 4: Coding Based on Medical Decision Making
