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Home > Practice & Professional Development Library > Time and Its Role in E/M Services

Time and Its Role in E/M Services

By W. Bruce Milliman, ND, and Eva Miller, ND
(AMA - CPT/Editorial Panel/HCPAC, representing the AANP)


In the naturopathic profession, time is a very important component of our encounter with patients. Naturopathic physicians believe that they spend more time with patients than other healthcare practitioners and that insurance doesn’t reimburse for that extra time (until now, time was not a component that was reimbursable – read on).

This article will cover the component of time and its role in E/M services.

As written in CPT Professional Edition 2011
“Intraservice time” is the type of time that is used to measure the total amount of time and work associated with E/M (Evaluation and Management) services. “Intraservice times are defined as face-to-face time for office and other outpatient visits and as unit/floor time for hospital and other inpatient visits.”

“For coding purposes, face to face time for these services is defined as only that time that a physician spends face-to-face with the patient and/or family. This includes the time in which the physician performs tasks such as obtaining a history, performing an examination and counseling the patient.”

It is important to note that time spent before and after a patient visit performing such tasks as reviewing records, arranging for further services, and communicating with other professionals is not included in the time component described in the E/M codes. This is called “non-face-to-face” time or “pre- and post-encounter time.”

Important News for Naturopathic Practice and Reimbursement
Effective January 1, 2011, the CPT manual has been revised to state that: “When counseling and/or coordination of care dominates (more than 50%) of the physician/patient and/or family encounter, then time shall be considered the key or controlling factor to qualify for a particular level of E/M services. The extent of counseling and/or coordination of care must be documented in the medical record.”

Until 2011, the bolded and italicized “shall” was “may.” This change is of paramount importance to the naturopathic community because time spent with patients in counseling and/or coordination of care is that for which the profession has wanted to get reimbursed. This recognition of time throughout the healthcare system is a remarkable and important change! This change moves the United States towards a healthcare system which invests in wellness and health promotion. This one word change supports naturopathic physicians and other providers who “treat disease by restoring health” (AANP Definition of Naturopathic Medicine Position Paper 1989).

Dr. Milliman, as Advisor representing the AANP on the Health Care Professionals Advisory Committee for CPT has brought this issue forward repeatedly; in addition Dr. Michelle Simon (HOD/Washington) carried this message to a recent Institute of Medicine (IOM) meeting. We as a profession are pleased to have one of our major components of patient care (counseling time) fully recognized nationally by CPT.