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Coding Office and Outpatient E/M Visits Based on Time
Linda Tauber, CPC, CPMA, CRC, CPB
Certify Me Now Medical Coding
Office and outpatient E/M levels may be selected by
medical decision making or by the
billing practitioner's total qualifying time on the date of the encounter.
Choosing the correct evaluation and management level does not always have to be
based on medical decision making. For office and outpatient E/M services, the
code may be selected using either medical decision making or the physician's or
other qualified healthcare professional's total time on the date of the encounter.
CPT® does not give preference to one method over the other. Time may be especially
helpful when the practitioner performs extensive counseling, record review, care
coordination, or other qualifying work, but the documented medical decision making
supports a lower level.
A common misconception is that only time spent in the examination room counts.
When an office or outpatient E/M code is selected based on time, both face-to-face
and qualifying non-face-to-face work may be counted.
- Personally performed by the physician or other qualified healthcare professional;
- Related to the patient's E/M service; and
- Performed on the date of the encounter.
The time does not have to be continuous. Qualifying work performed before,
during, and after the face-to-face portion of the visit may be combined.
| CPT® Code | Total Time on the Date of the Encounter |
|---|---|
| 99202 | 15–29 minutes |
| 99203 | 30–44 minutes |
| 99204 | 45–59 minutes |
| 99205 | 60–74 minutes |
| CPT® Code | Total Time on the Date of the Encounter |
|---|---|
| 99211 | Time is not used for code selection |
| 99212 | 10–19 minutes |
| 99213 | 20–29 minutes |
| 99214 | 30–39 minutes |
| 99215 | 40–54 minutes |
The minimum time for the selected code must be met. A total of
29 minutes for an established patient falls within
99213; it does not support 99214.
Qualifying practitioner activities may include:
- Preparing to see the patient, including reviewing relevant records or test results.
- Obtaining or reviewing a separately obtained history.
- Performing a medically appropriate examination or evaluation.
- Counseling and educating the patient, family, or caregiver.
- Ordering medications, tests, or procedures.
- Communicating with other healthcare professionals when the communication is not separately reported.
- Documenting clinical information in the health record.
- Independently interpreting results when the interpretation is not separately reported.
- Communicating results to the patient, family, or caregiver.
- Coordinating the patient's care.
Only the time actually spent performing these activities should be counted.
Do not include:
- Clinical staff time.
- Time spent by students.
- Work performed on a different date.
- Travel time.
- General teaching that is not required for the management of the individual patient.
- Time spent performing a procedure or another service that is separately reported.
- Time spent interpreting a test when the interpretation is separately billed.
- Duplicated time when more than one practitioner is simultaneously caring for the patient.
- Time associated with work that is not medically necessary.
The same minute cannot be counted toward two separately reported services.
When an E/M service and a procedure are reported on the same date, the time
spent performing the procedure and its usual pre-service and post-service work
cannot be included in the E/M time.
The medical record must also support that the E/M service was significant and
separately identifiable from the procedure before modifier 25 is appended.
documents 22 minutes of separate E/M work and excludes all time
associated with the injection.
If the E/M service is significant and separately identifiable, the documented
E/M time may support 99213. The injection time cannot be added
to reach the next E/M level.
When time is used to select the E/M level, the medical record should clearly
state the total qualifying time personally spent by the billing practitioner
on the date of the encounter.
The practitioner is not generally required to document the exact number of
minutes spent on every individual activity. However, the note should identify
the qualifying work performed and demonstrate that the total time was reasonable
for the patient's condition and the services provided.
"Total time personally spent by me on the date of this encounter was ___ minutes.
This included [list the qualifying activities actually performed]. Time associated
with separately reported services was excluded."
Do not use a standard list claiming that every activity was performed at every
encounter. The statement should reflect the actual work completed for that patient.
An established patient is seen for follow-up of a stable condition. The medical
decision making supports a low level. However, the practitioner spends:
| Qualifying Activity | Time |
|---|---|
| Reviewing outside records before the visit | 7 minutes |
| Evaluating and counseling the patient | 18 minutes |
| Documenting and coordinating follow-up care after the visit | 8 minutes |
When the time is medically reasonable and properly documented,
99214 may be selected based on time even though the MDM
alone supports a lower level.
Documenting enough minutes does not automatically justify a higher-level service.
The total time must be reasonable and necessary for the patient's condition and
the work performed.
- Repeatedly reporting identical times for multiple patients.
- Using unusually high time levels without explaining the work performed.
- Counting staff or procedure time.
- Including work performed on another date.
- Copying a time statement that does not match the encounter.
- Reporting more time than could reasonably have been performed during the practitioner's schedule.
The diagnoses, assessment, plan, services performed, and documented time should
all support one another.
Prolonged services may be considered when the highest office or outpatient E/M
level is selected based on time and the applicable prolonged-service threshold
is met.
-
Medicare generally uses HCPCS code G2212 for qualifying
prolonged office or outpatient E/M time. - Some non-Medicare payers may recognize CPT® code 99417.
- The minimum time thresholds for G2212 and 99417 are not the same.
Never assume that a commercial payer follows Medicare's prolonged-service policy.
Verify the payer's current requirements before submitting the claim.
The office and outpatient time ranges do not apply to every type of E/M service.
Emergency department visits, preventive medicine services, critical care, hospital
services, nursing facility services, and home or residence services have their own
coding requirements.
Always confirm that the E/M category allows time-based code selection and apply
the rules specific to that code family.
Count the practitioner's qualifying time.
Count only work performed on the date of the encounter.
Exclude separately reported services.
Document the total time clearly.
Time-based coding can support accurate reimbursement, but only when the
documentation demonstrates the actual, medically necessary work performed.
Guidance reviewed: August 30, 2026
This article is based on the following authoritative E/M resources.
Coding and payer policies may change, so the current code set and
payer-specific instructions should be reviewed before claims are submitted.
- American Medical Association: Documenting and coding office/outpatient E/M services by time.
- American Medical Association: When to bill by MDM versus time (2026).
- Centers for Medicare & Medicaid Services: Evaluation & Management Services.
Educational Notice:
This document is intended for educational purposes. Always consult the current
CPT® code set, CMS guidance, NCCI edits, and individual payer policies before
submitting claims. CPT® is a registered trademark of the American Medical Association.
Certify Me Now Medical Coding provides practical medical coding education
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