How Billing Code Times are Calculated

Billing Codes: Untimed vs. Direct Timed vs. Pseudo-timed

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Typically, the CPT codes used to bill for rehab therapy services fall into one of two categories: untimed or direct timed. In WebPT, these two categories of codes appear in the billing area of the documentation—that is, within the Billing tab of an evaluative note or the Objective tab of a Daily Note. However, there are a few outliers to this CPT code dichotomy: pseudo-timed codes. Before we get into the details of pseudo-timed codes, though, let’s review the differences between untimed and direct timed codes as well as how to bill for each.

Untimed Codes

Example of Untimed Codes located within the billing area of WebPT documentation

Within the Healthcare Common Procedure Coding System (HCPCS), certain services—and the codes designating those services—are not defined by a specific timeframe. These codes are known as “untimed,” meaning the provider can only charge for one unit, regardless of the amount of time he or she spent performing the service (in many cases, that means the provider can only bill one unit per date of service).

Example of Using an Untimed Code in WebPT

Here’s an example: a therapist performs a physical therapy evaluation for a new patient, a service indicated by the CPT code 97001. Regardless of the amount of time the therapist spent providing the evaluation, he or she would charge for one unit. For payers that follow the 8-minute rule—including Medicare—the therapist still must document the number of minutes he or she spent on each service (even those that are untimed). To make this easy, WebPT provides a special checkbox for untimed codes. That way, only one billing unit is charged out for that service.

In the example shown below, the provider spent 30 minutes performing the PT evaluation. Because the patient has Medicare—which uses the 8-minute rule—the therapist must indicate the number of minutes he or she spent providing the evaluation. The system will then add those minutes to the number of Total Treatment Minutes, which displays at the top of the billing section. But because the user checked the box, the system will automatically bill only one unit for the service.

Untimed Code example

Direct Timed Codes

Example of Direct Timed Codes located within the billing area of WebPT documentation

When a therapist performs a service indicated by a direct timed code, the number of units the therapist can bill for that service depends on the amount of time he or she actually spent delivering the modality. Please note that any time spent performing unskilled pre- and post-delivery services (i.e., preparation and cleanup) does not count toward the treatment service time. In other words, the time counted as part of the “intra-service care” total begins when the therapist or physician—or an assistant under the supervision of a physician or therapist—is directly working with the patient to deliver treatment services. At that point, the patient should already be in the treatment area (i.e., on the treatment table or mat, or in the gym) and prepared to begin treatment.

Many of the CPT codes used for therapy modalities, procedures, and tests and measurements specify that each unit of the code represents 15 minutes of direct (i.e., one-on-one) time spent in patient contact. To bill for the services provided on a single date of service (i.e., single calendar day), providers report procedure codes for services delivered along with the appropriate number of 15-minute service units.

Example of Using a Direct Timed Code in WebPT

Here’s another example: a therapist spends 15 minutes of direct time with the patient performing therapeutic exercise. As shown in the image below, the provider types “1” next to “Therapeutic Exercise” (CPT code 97110) and indicates the time spent providing this service, as the patient’s insurance is Medicare. The system will then add these minutes to the number of Total Direct Minutes, which displays at the top of the billing section.

Direct Timed Code Example.

If you’re billing a payer that follows the 8-minute rule, please see this article for specifics on units and minutes.

Pseudo-timed Codes

Pseudo-timed codes currently are not defined by CMS. However, CMS is proposing to distinguish a separate category of “direct timed codes” that fit the following definition: CPT codes that are defined by a specific timeframe other than the traditional 15-minute interval. For the purposes of this article, we will refer to those codes as “pseudo-timed.”

Here are some examples of pseudo-timed codes:

96125 - Standardized cognitive performance testing, per hour (OT)96105 Assessment of aphasia, per hour (SLP)97545 - Work hardening/conditioning, first hour (OT)97546 Work hardening/conditioning, each addl hour (OT)92607 Evaluation for prescription alternative comm device, first hour (SLP)92608 Evaluation for prescription alternative comm device, each addl 30 mins  (SLP)92626 Evaluation Auditory Rehab Status, first hour (SLP)

Many of these codes appear within the Direct Timed section of the WebPT billing area. Thus, the system will add the minutes spent performing these services to the number of Total Treatment Minutes, which displays at the top of the billing section.

Examples of Using Pseudo-timed Codes in WebPT

EXAMPLE 1

An OT spends three hours on work hardening/conditioning. In the Direct Timed Codes section of the billing area in WebPT, the therapist will locate “Work hardening/conditioning; initial 2 hours,” charge for one unit, and indicate 120 minutes for this code. Then, to account for the remaining hour of treatment time, the provider will charge for one unit of “Work hardening/conditioning; each additional hour” and indicate 60 minutes for this code. The system will add all 180 minutes spent performing this service to the number of Total Treatment Minutes, which displays at the top of the billing section.

Pseudo-timed code example

EXAMPLE 2

An SLP spends two hours performing an evaluation for a prescription alternative communication device. The provider will charge for one unit of “Evaluation for speech-generating augmentative/alternative device; first hour” and indicate 60 minutes for this service. Then, to account for the second hour of treatment time, the provider will charge for two units of “Evaluation for speech-generating augmentative/alternative device; each additional 30 min” and indicate 60 minutes for this service. The system will add all 60 minutes spent performing this service to the number of Total Treatment Minutes, which displays at the top of the billing section.

Pseudo-timed code example

Pseudo-timed Codes FAQ

Should I bill pseudo-timed codes by units (the same way I would bill a 15-minute unit for a direct timed CPT code)?

Yes. Because pseudo-timed codes are time-specific by definition, they should be billed in units; however, the 8-minute rule does not apply to these codes. Instead, if the provider spent more than 50% of the specified time providing skilled therapy treatment to the patient, then per HCPCS guidelines, it is appropriate to bill one unit. On the other hand, if the provider spent less than 50% of the specified time with the patient, then the provider would not bill for any units (i.e., the provider would enter “0” for the number of units). This is similar to a situation in which a provider spends 7 minutes performing a service that falls under the 8-minute rule.

Should I include the minutes associated with pseudo-timed codes in the Total Direct Minutes (like I do with 15-minute codes)?

No. While these codes are referred to as “timed codes” in section 20.4 of the Medicare Claims Processing Manual, the section separates them as specialized codes and provides alternate instructions on what was considered “treatment” for the purposes of billing these codes. However, the documentation is silent on the issue of billing pseudo-timed codes with 15-minute codes on a single claim; the application of the 8-minute rule to these specialized timed codes; and the minute ranges that yield a single unit. Therefore, including the minutes for pseudo-timed codes in the Total Direct Minutes calculation prevents accurate application of the 8-minute rule. This is because, without further definition of pseudo-timed codes and examples of how to bill these specialized codes in conjunction with 15-minute codes, it would be impossible to accurately calculate the appropriate number of units. For that reason, the specialized code minutes should not be included in Total Direct Minutes.  

Then how do you account and bill for the treatment time associated with pseudo-timed codes?

The total number of minutes billed for pseudo-timed codes will be added to the Total Treatment Minutes—similar to an untimed code. Therefore, WebPT will not edit-check the correct number of units for pseudo-timed codes; rather, the system will accept the number of minutes entered for the code and add them directly to the Total Treatment Minutes.

What are some key takeaways about pseudo-timed codes?
  • Timed codes that are not billed in 15-minute units are distinguishable timed codes (i.e., pseudo-timed codes).
  • CMS has not provided any guidance on how to bill timed codes with mixed-time intervals (i.e., 15-minute codes with pseudo-timed codes).
  • Pseudo-timed codes, therefore, require units, per HCPCS guidelines.
  • Pseudo-timed codes require treatment minutes.
  • Minutes spent providing services associated with pseudo-timed codes are treated like untimed code minutes. Thus, those minutes will be added to Total Treatment Minutes.
  • Minutes spent providing services associated with pseudo-timed codes are not treated like timed code minutes. Thus, those minutes will not be added to Total Direct Minutes.
Where can I find more information about pseudo-timed codes?

CMS does not specifically define pseudo-timed codes. Sections 20.2 and 20.3 of the Medicare Claims Processing Manual explains the difference between timed and untimed codes as well as how to bill for each. However, the majority of this document is dedicated to guidance on the correct application of the 8-minute rule when billing untimed codes and 15-minute direct timed codes. Section 20.4 deals specifically with non-15-minute timed codes (which, confusingly, are also referred to as “timed codes”). Still, this section does not provide any guidance on combination billing (i.e., billing pseudo-timed codes with normal 15-minute timed codes) or correct application of the 8-minute rule in such instances.  Citations from CMS:
Medicare Claims Processing Manual, Section 20.2, 20.3. 20.4
https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c05.pdf