Prolonged Services: Non-Face-to-Face
As of 1/1/2017, CMS authorized non face-to-face prolonged services (CPT codes 99358‒99359) as payable services. In conjunction with this approval, CMS released MLN Matters® MM9905: Prolonged Services Without Direct Face-to-Face Patient Contact Separately Payable Under the Physician Fee Schedule (Manual Update) which includes introductory information.
Code Definition
Unlike the face-to-face prolonged services codes (99354‒99355 and 99356‒99357), the non-face-to-face prolonged services codes (99358‒99359) are not add-on codes, and may be billed without the presence of a base E/M service on the claim. They must, however, be directly tied to a billed face-to-face service performed by the same rendering/billing provider. Time spent in performing these services must meet or exceed 30 minutes beyond the suggested time for the associated face-to-face service.
As per the 2017 CPT manual, these codes are defined as applicable in the office and outpatient setting and in the hospital and nursing facility setting. The services are also defined as billable in relation to other physician or other qualified health care professional services, including E/M services, at any level.
The code(s) may be reported on the same or different date than the primary service to which it is related, and must be related to a service where (face-to-face) patient care has occurred or will occur. In addition, there must be clear medical necessity for the service as key to patient management.
The codes may be used to represent time spent (30 or more minutes) reviewing extensive medical records on a date prior or subsequent to a new patient encounter; an entry in the medical record should describe this activity and the time spent. Documentation for 99358‒99359 should always include reference to the face-to-face service that supports the medical necessity for the non-face-to-face service.
The codes may be used to represent extensive telephone time (30 or more minutes) with the patient and/or a responsible family member. Again, the telephone time must be linked to a face-to-face encounter which may occur either prior or subsequent to the telephone discussion. Notation of the telephone time, including the date, time, general topic and identity of the telephone call participant must be noted in the medical record as soon as possible after the call.
Finally, the codes may be used to represent time spent in a family or caregiver meeting without the patient’s presence, when the meeting time meets or exceed 30 minutes beyond the associated face-to-face service and when the meeting is medically necessary as part of patient management. The medical record for this service should include the date, time and attendees at the meeting, the general meeting topic and outcome and the face-to-face patient service to which the meeting is related.
CPTs 99358‒99359 are not to be used in collaboration with CCM, TCM, nor with CPO, anti-coagulant management, medical team conferences and online medical evaluations.
Provider Guidance
Providers should remain aware of the need for explicit documentation describing each episode in which these codes are billed to Medicare. Medical records must support the medical necessity of the service, the time spent and the fact that the service was not duplicated by other billed services, (e.g., E/M services or as part of a global surgical service).