The billing and coding workshop spent appropriately little time on the 40 minutes we lost from the highest level of time-based consultant billing, but also paid too much attention to complexity-based billing, in my opinion. Since much of the work I do as a palliative care consultant is counseling and care planning, and little of that face to face, prolonged service codes aren’t very useful to me, and I end up really trying to do the basic work of each consult inside that 70 minutes…which doesn’t leave much time for a complex exam, does it? So complexity-based billing doesn’t provide any advantage for that first visit. I’ll admit it’s worth thinking about complexity-based billing for subsequent visits, 99233s or 99310s in hospitals or nursing homes, respectively. So the issue of complexity-based vs time-based billing could be simplified: time-based for initial visits, complexity-based for subsequent visits.
Patrick Clary, MD
Medical Director Exeter Hospital Palliative Care (etc)
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