I also bill new patient EM based on counseling time when I am in with them more than 20 minutesc BUT I understand the counseling time should be with regard to their ongoing care, referrals, ADL modifications, treatment options, additional tests that may be needed, etc. Personally, I dont count explaining the theory of chiropractic. Chirocode makes a nice form to document this. I think it's on their website chirocode.com. It may be cleaner to use the additional time code.