Health Information Management

Q&A: Typical time for CPT initial observation codes

JustCoding News: Outpatient, January 11, 2012

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QUESTION: The 2012 CPT® Manual includes the typical time physicians spend at the bedside and on the patient’s hospital floor or unit for initial observation care codes 99218, 99219, and 99220. Do these codes only apply when the counseling and/or coordination of care support the respective 30/50/70 minutes of time? Do you know if CMS has published any new guidelines related to these times?

ANSWER: CPT guidelines state that these time measurements have not been revised as of January 1, 2012. They are general indicators of the approximate time a physician might spend physically on the floor in the patient’s unit and at bedside while he or she is adding to and/or reviewing the patient’s chart, performing a physical examination on the patient, writing (dictating) notes, and spending time communicating with other healthcare professionals, the patient, and the patient’s family.

The times are not part of the code description, just a general guide for each level. Report the code that most accurately represents the tasks performed not the time spent.

Editor’s note: Shelley C. Safian, PhD, MAOM/HSM, CCS-P, CPC-H, CHA, of Safian Communications Services in Orlando, FL, answered this question. She is a senior assistant professor who teaches medical billing and insurance coding at Herzing University Online in Milwaukee, WI. E-mail her at

This answer was provided based on limited information submitted to JustCoding. Be sure to review all documentation specific to your own individual scenario before determining appropriate code assignment.

Need expert coding advice? Submit your question to Senior Managing Editor Michelle Leppert, CPC-A, at, and we’ll do our best to get an answer for you.


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