Yes, I'm talking about a psychiatrist spending say 25 minutes face-to-face with a patient being treated with meds. Greater than 50% of that time is spent COUNSELING about things like:
Diagnostic results, impressions, Prognosis, Risks and benefits of treatment, Instructions for med/symptom management and/or follow-up, Importance of med compliance, Risk factor reduction (smoking cessation, alcohol cessation), Patient and family psychoeducation.

I am NOT talking about the psychiatrist doing any psychotherapy defined by CPT as: Advice and Teaching, Reassurance & Encouragement, Rationalizing and Reframing, Anticipatory Guidance, Reducing and Preventing Anxiety, Naming the Problem, Expanding the Patient’s Awareness. Doing psychotherapy would mean adding on the new psychotherapy code. I'm talking about straight E&M BUT time based if COUNSELING is > 50% of total session.