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§E/M codingUpdated

Should you bill an office visit by time or by MDM?

Either one, chosen visit by visit. Time fits visits where counseling, record review or charting took the clinician's day; medical decision making fits visits where the decisions carried the weight.

By , Chief Medical Officer


You can use either one, and you choose for each visit. CPT and Medicare let you set an office visit's level by medical decision making (MDM) or by the clinician's total time on the day of the visit, so pick the method that matches the work the note shows.

Time fits visits where counseling, reviewing records, or charting filled the clinician's day. MDM fits short visits where the decisions were complex. Whichever you pick, the note has to back it, and the level can come out lower as easily as higher.

How many minutes does each office visit code need?

Here are the times and MDM levels for office visits. Medicare and CPT use the same numbers. When you use time, the clinician has to reach the full number of minutes, so 29 minutes is still a 99213.

CodePatientTime starts atOr MDM at least
99202New15 minutesStraightforward
99203New30 minutesLow
99204New45 minutesModerate
99205New60 minutesHigh
99212Established10 minutesStraightforward
99213Established20 minutesLow
99214Established30 minutesModerate
99215Established40 minutesHigh

99211 sits outside this table. It's for a visit where clinical staff, like a nurse or medical assistant, provide the service under the clinician's supervision, so neither time nor MDM sets it.

Past the top level, Medicare pays extra time with its own add-on code, G2212. For an established patient, the first unit starts at 69 minutes of total time.

What counts toward the clinician's time?

Time means everything the physician or other billing clinician personally does for that patient on the date of the visit, in the room or not, in the office or not. The AMA lists what counts:

  • preparing to see the patient, like reviewing tests
  • getting or reviewing history from records or another source
  • the exam
  • counseling and educating the patient, family, or caregiver
  • ordering medications, tests, or procedures
  • talking with other clinicians, when it isn't billed separately
  • documenting in the chart
  • reading results yourself and explaining them to the patient, when not billed separately
  • coordinating care, when not billed separately

And what doesn't:

  • anything the medical assistant or nurse does, like rooming the patient or taking vitals
  • time on any other day, like reading the chart the night before
  • time spent on a service billed on its own, like a joint injection
  • travel, and general teaching that isn't about this patient's care

Write down the total time or the start and stop times. CMS accepts either. A template that stamps "25 minutes" on every note doesn't count as either.

What happens when time and MDM give different levels?

A 58-year-old with high blood pressure comes in worried. Her sister had a stroke last month, and she wants to know her own risk. Her blood pressure is at goal on lisinopril, and nothing about her treatment changes. Here's how the doctor's day with her adds up:

What happened on the day of the visitMinutesCounts toward time?
Doctor reviews her cardiologist's note before she arrives6Yes, preparing to see the patient
Medical assistant rooms her, takes vitals, updates the medication list8No, clinical staff time
Doctor talks through her stroke risk, warning signs, blood pressure goals, diet and walking22Yes, counseling and education
Doctor writes the note after she leaves5Yes, documenting
Clinician total33Supports 99214 by time

Now read the same visit by MDM. She has one stable chronic illness, which is a low-level problem. One outside note reviewed doesn't reach the data a low level asks for. She stays on the same lisinopril dose, and even if a reviewer counts that as prescription drug management, two of the three elements still sit at low or below. MDM supports a 99213.

So this visit gets billed by time as a 99214, with a line like this in the note:

Total time on the date of service: 33 minutes, including review of cardiology records, counseling on stroke risk and blood pressure goals, and documentation.

Flip it around and MDM wins. A 15-minute visit where the doctor adjusts insulin for a patient whose A1c is climbing is a 99212 by time. By MDM it has a worsening chronic illness and prescription drug management, which is moderate, so it supports a 99214. See how MDM reaches a 99214.

What should you check before you sign?

  1. Which method supports the level, MDM or time?
  2. If MDM, does the assessment and plan show today's decisions for each problem? A pasted problem list doesn't. See what counts as a medication decision.
  3. If time, is the clinician's total time for today written in the note, without staff time or another day's work?
  4. Would a lower level describe the visit better? If so, bill the lower level.

CMS puts medical necessity first and says it wouldn't be appropriate to bill a higher level when a lower one fits. History and exam must be medically appropriate, but they don't set the level. This is Medicare's rule, and most commercial plans follow CPT the same way; check each plan's policy for prolonged time codes.

Cortex Lens reads each Practice Fusion note while the chart is still open and shows the level its medical decision making supports, 99212 to 99215, up or down. When the clinician spent longer than that level suggests, the note needs the total time written down before it's signed.

Sources: Choosing MDM or time, full time required, history and exam, and medical necessity: CMS, Evaluation and Management Services, MLN006764, May 2026, pages 23–24; prolonged time with G2212: the same booklet, Table 3 on page 15. What counts toward time: AMA, 2023 CPT E/M Descriptors and Guidelines, pages 19–20; MDM levels: the same document, Table 1 on pages 8–10. Time and MDM for 99214: AMA, CPT code 99214, updated January 26, 2026.