Welcome to my blog, a place to explore and learn about the experience of running a psychiatric practice. I post about things that I find useful to know or think about. So, enjoy, and let me know what you think.

Friday, April 18, 2014

Documentation of Time

I thankfully haven't felt the need to write anything about E/M coding in a while. But there seems to be an important update.

The NYSPA will host a Psychotherapy Documentation Update Webinar on April 29th (I couldn't find any information about it on the NYSPA site, so the link is to the registration form):

NYSPA will be hosting a webinar to update members on new documentation requirements requiring documentation of psychotherapy time. The webinar will address the new Medicare and Optum policy on documentation of time. Discussion will include the revised NYSPA template, status of health plan audits and parity issues.

It's free to NYSPA members, and $250 for non-members. And it will be posted to the website afterwards, for those members who couldn't make the webinar.

Time has been a bit of a sticky point in terms of E/M, CPT coding. A lot of people were concerned about the requirements to document time spent doing psychotherapy separately from time spent doing Evaluation and Management. When I attended the coding seminar given by NYSPA, we were assured that since psychotherapy is not a separate event from evaluation and management, the times for the two should just be mushed together.

Apparently, United Behavioral Health/Optum was denying claims for just this reason:

Optum was refusing to provide reimbursement for the psychotherapy add-on code because the provider had failed to document start and stop times for the psychotherapy portion of the session alone (as opposed to the E/M portion). This practice, clearly in violation of CPT, was being applied to both in-network and out-of-network benefits. (Source, from NYSPA)

NYSPA was contacted, and the APA got involved, and ultimately:

UBH/Optum... acknowledged that the new combination psychotherapy codes represent the provision of a single integrated service that cannot and should not be separated out.   As a result, UBH/Optum will discontinue its requirement that psychiatrists record the time spent providing psychotherapy alone. ...Please note, however, that proper documentation of psychotherapy must include session start and stop times and/or the total face-to-face time spent with the patient. (Same Source).

Optum subsequently sent a letter to providers confirming E/M documentation guidelines.

I'm not sure what the webinar will cover with respect to medicare documentation. My take home lesson is: Include start and stop times in my notes.

And while I was poking around the cms.gov site looking for and not finding information about documenting psychotherapy time, I did find:

Medicare Coverage of Items and Services Furnished to Beneficiaries in Custody Under a Penal Authority Crossword Puzzle. (The link goes to the page that links to the zip file with the pdf of the puzzle.) It looks like this (so you know I didn't make it up):


  1. Looking forward to your synopsis

    1. Thanks, but I don't feel like sitting through the whole seminar, so I'm just going to document start and stop times and call it a note.

  2. In addition to scribes physicians of the future will have timekeepers who record start and stop times according to industry standards. Will they work for the payers or the physician? If for the physician we will need new laws to discourage timekeeping fraud, like starting the stopwatch when greeting the patient in the waiting room instead of waiting for the treatment room door to close. Will pleasantries about traffic and weather be counted? What about the time it takes for the patient to turn off that cell phone?

  3. This is a smart blog. I mean it. You have so much knowledge about this issue, and so much passion. You also know how to make people rally behind it, obviously from the responses.
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