If you are the kind of provider who spends real time with patients, reviewing records before the visit, counseling carefully, coordinating afterward, time-based coding is how that diligence finally gets counted. Since January 1, 2021, you can select any office or outpatient E/M code based on total time spent on the patient's care on the date of the visit, no need to show that counseling "dominated" the encounter. This change dramatically expanded when time-based coding is useful.
What Counts as Total Time
Total time for office visit coding includes any of the following activities performed by the physician (or qualified health professional) on the same calendar date as the visit:
- Preparing to see the patient (reviewing records, labs, imaging before the visit)
- Obtaining and reviewing separately obtained history
- Performing the examination and evaluation
- Counseling and educating the patient or their family
- Ordering and reviewing test results
- Arranging referrals and communicating with other providers
- Documenting the clinical information (writing the note) in the EHR
- Independently interpreting results
Clinical staff time does not count. The medical assistant's intake time, the time the patient spent in the waiting room, and time spent on administrative work unrelated to the patient's care are excluded.
The Time Thresholds (Office and Outpatient)
| CPT Code | Patient Status | Total Time Range | wRVUs |
|---|---|---|---|
| 99202 | New | 15–29 min | 0.93 |
| 99203 | New | 30–44 min | 1.60 |
| 99204 | New | 45–59 min | 2.60 |
| 99205 | New | 60–74 min | 3.50 |
| 99212 | Established | 10–19 min | 0.70 |
| 99213 | Established | 20–29 min | 1.30 |
| 99214 | Established | 30–39 min | 1.92 |
| 99215 | Established | 40–54 min | 2.80 |
When Time Works Better Than MDM
Time-based coding tends to support a higher code level than MDM in visits that are heavy on counseling, care coordination, or discussion, even when the clinical complexity in the MDM table would fall at a lower level. Classic examples:
- A patient with a new diagnosis who requires extensive education and counseling about their condition and treatment options. The MDM might reflect a moderate-complexity problem, but you spent 45 minutes on the visit.
- A complex patient where you spent significant time before the visit reviewing outside records, imaging, or specialist notes. That pre-visit time counts.
- A patient with multiple specialists whose care you are actively coordinating, generating significant same-day phone calls and documentation.
How to Document Time-Based Coding
Documentation is simple but non-negotiable: your note must state the total time. A line like "Total time spent in preparation, evaluation, counseling, and documentation for today's visit: 42 minutes" is all that is required from a basic standpoint. Some providers also briefly describe what the time was spent on, which strengthens the claim and is good clinical practice regardless.
Prolonged Services: When You Go Beyond the Highest Threshold
If your total time exceeds 54 minutes for an established patient (the upper bound of a 99215), you can add a prolonged services code on top of the 99215. This is covered in detail in Chapter 11. The key rule: the highest E/M level must first be selected by time before prolonged service codes can be added.