• Selecting a code for an E/M service can be based on time or medical decision making (MDM) (except ED visits which must be selected based on MDM)
• Time includes all time spent by the billing practitioner on the date of service, not just face-to-face time, and counseling does not need to dominate the visit, as it did in the 1995/1997 guidelines
• The practitioner does not need to meet both MDM and time
• This article discusses when to use time to select a level of E/M service
• Time Statements for E/M Visits: What Coders and Providers Need to Know

Per the AMA’s 2023 CPT® Evaluation and Management (E/M) Code and Guideline Changes rules for using time to select a level of E/M service are  the same, whether done in the office, the hospital or nursing facility.  A practitioner may use total time on the date of service, and counseling doesn’t need to be more than 50% of the face-to-face time. If you haven’t changed your templates that read, “I spent 30 minutes face-to-face with the patient, more than half of which was in counseling and coordination of care,” do that now. (We’re still seeing this used even on the cusp of 2026!) Document total time spent and what was done. (Examples later in article.)  Avoid time statements that all use the time in the code descriptor.

CPT® rules

The CPT® rules allow all of these activities, listed below, to be included in the total time, used to select an E/M CPT® code. Do not count staff time in performing these activities.

Physician/other qualified health care professional time includes the following activities, when performed:

• preparing to see the patient (eg, review of tests)
• obtaining and/or reviewing separately obtained history
• performing a medically appropriate examination and/or evaluation
• counseling and educating the patient/family/caregiver
• ordering medications, tests, or procedures
• referring and communicating with other health care professionals (when not separately reported)
• documenting clinical information in the electronic or other health record
• independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver
• care coordination (not separately reported)

Time Statements for E/M Visits: What Coders and Providers Need to Know

Time-based coding for Evaluation and Management (E/M) services can be a powerful tool, but only when used correctly. Incomplete or vague documentation of time can lead to denials, audits, and compliance issues. Here’s a breakdown of the best and worst practices when documenting time for E/M visits.

Time Statements: What to Avoid

Too Short: “Time Spent” with No Details

Simply stating “30 minutes spent with patient” isn’t enough. Without a description of the work performed, it’s most certainly impossible to justify the level of service.

Why It Fails: Payers need to see what was done during the time stated (e.g., history review, time with the patient, counseling, coordination of care after the visit, documentation, etc).

Too Vague: Greater Than or Less Than

Statements like “>30 minutes” or “less than 15 minutes” are ambiguous and lack clarity. These phrases don’t align with CPT guidelines, and they do not support precise code selection.

Why It Fails: Coding requires specific time ranges and vague estimates do not meet CPT documentation standards.  Internal and external auditors won’t credit these.

Teaching Physician Time Not Clearly Documented

When residents or fellows are involved in direct patient care, the attending physician’s time spent in direct patient care versus time spent in teaching the resident or fellow must be clearly documented. Statements like “I personally spent 40 minutes outside of teaching time with the patient discussing treatment, reviewing records, and documenting in the chart”, make it clear that only direct patient care time was used in calculating the level of service.

Why It Fails: Only the time the teaching physician spends outside of teaching activities counts toward E/M coding. CMS requires clear delineation, and most major commercial carriers follow CMS guidelines as well.

Best Time Statements: What to Include

Specific Time + Description of Activities

“I spent a total of 35 minutes discussing the patient’s new diagnosis of diabetes, medication options, and lifestyle changes.”

 Clear Separation of Teaching Time

“Total time spent: 40 minutes. Of this, 25 minutes were direct patient care by the attending physician, excluding time spent teaching the resident.”

Time Range Matching CPT Guidelines

“Total time: 60 minutes, used for reviewing labs, discussing treatment options, and coordinating care with the patient’s cardiologist.”

Specific time documentation supports accurate coding, protects against potential paybacks, and ensures fair reimbursement. A great rule of thumb is to be specific, clear, and always tie documentation of time back to the work performed.

Additional resources

• Care management codes
• Transitional care management
• Interprofessional consults
• Remote physiological management