by Timothy Gieseke, MD, CMD

CPT Codes have existed since 2007 that have encouraged documentation of non-face to face (FTF) time for the first hour beyond the usual expected time of the visit (99358).  In practice this means 31 minutes or more, based on CPT guidance.  There is also a subsequent code (99359) for every 30 minutes (really 16 minutes or more) beyond the first hour thereafter.  However, a payment hasn’t previously been approved for these codes.  As of January 1, 2017, a payment has been assigned to these codes.  This means that the non-FTF time spent reviewing incoming records, the hospital EHR, and the time spent contacting clinical information sources for important information, are potentially billable.   This code applies to a new patient encounter or an established hospitalized patient returning to the office, home, or SNF setting.  The non-FTF services can occur before, same day, or after the day of FTF E/M assessment.  However, the non-FTF services must occur all on the same day and should be billed separately with a statement of what was done and the time of each of these services, that are then attested, signed and dated by the clinician.

If this were a new SNF admission for post-acute care that merited the 99306 charge (i.e. 75 min. of FTF E/M service expected), as long as >31 min. of same-day non-FTF time occurred, the 99358 code could be added.  The 99359 code is for each additional 30 min. of non-FTF time beyond the 60 minutes included in the 99358 code.  Please access the Nicoletti newsletter on this subject for more information as well as the report from the Medicare-Learning-Network.

As a SNFist, I have provided the above services for no added charge for many years, since it has allowed me to more precise in my assessment and care planning for new admissions.  My patients and their families appreciate these efforts to provide comprehensive care and often are grateful that I then take the time to help them make sense of what happened in the acute hospital and explain what will likely happen in the post-acute setting.

I’m glad that “doing the right thing” has now been recognized by CMS and can now be reimbursed.  As I reflect on my experience with non-FTF time in the care of my new post-acute patients, I will likely rarely spend enough same day non-FTF time , to use this code.  When possible though, the added payment for 99358 ($116 in my region) will be welcome.

If I had an office practice and were seeing a patient with a recent prolonged acute hospitalization or a medically complex new patient, I would be more likely to use this code on another day when the old records had become available for review at which time the remaining information gaps could be identified and phone calls made to address these gaps.

For those caring for fragile and medically complex patients in the Assisted Living, Home Bound, or PACE setting, these codes may reward the clinician and  patient (family) who now have an adequate data base for being more efficient (less duplicate testing) and precise in their shared health care decisions and plan.