11/21/2025    David Freedman, DPM

Coding Procedures with Time-Based E&M

Query: Coding Procedures with Time-Based E&M

I normally code an E&M visit with medical
decision-making. I have a new job that codes off
of time based visits. There are many denials for
the E&M when a procedure is performed. I am trying
to appeal these and am stuck when the denial is
upheld stating it’s inclusive with the procedure.
The documentation clearly states they were seen
for unrelated services and based on time before
during and after. Time does not include procedure.
Why is it still denied and how do I appeal this?

Codinghelpline com Subscriber

Response from Codinghelpline.com

Each E&M has time assigned to it but still
requires the provider to document time related to
only the non-procedure encounter portion of that
visit. For example, when billing time one must
state at least several of those listed below and
explain each one that contributed to “Total Time”:

i. Preparing to see the patient (e.g., review of
tests)

ii. Obtaining and/or reviewing separately obtained
history

iii. Performing a medically appropriate
examination and/or evaluation

iv. Counseling and educating the
patient/family/caregiver

v. Ordering medications, tests, or procedures

vi. Referring to and communicating with other
health care professionals (when not separately
reported)

vii. Documenting clinical information in the
electronic or other health record

viii. Independently interpreting results (not
separately reported) and communicating results to
the patient/family/caregiver

ix. Care coordination (not separately reported)

Your appeal would show the E&M for the service
that was time-based, discussing several of the
reasons for the time attributed to the medical
management provided. After all this is done, the
procedure should be in its own paragraph and
should be set up as a mini operative report as its
own paragraph outlining everything from what was
encountered that yielded the diagnosis, documented
the consent, the anesthesia administered, then
what was done using the surgical instrumentation,
applied post-op bandaging and care instructions
all unrelated to the E&M.

Take for example, the procedure CPT 11750. The
payer is expecting to see the pre-evaluation time
to be 17 minutes, pre-positioning time 3 min, pre-
service scrub wait time 5 min, Sx 15 min,
immediate post Sx time 7 min, this means the total
time is 47min for the procedure only.

When you append modifier 25, your last statement
should be the patient's condition required a
significant, separately identifiable E/M service
above and beyond the other service provided and
there was no overlap between the E&M and the
procedure.

David Freedman, DPM, Silver Spring, MD

Additional coding and billing questions and
responses can be found at Codinghelpline.com

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