Sorry if I haven't been clear. Think about a prescriber that today codes with lots of 90862s. The prescriber chooses to continue to NOT do psychotherapy (as 90862s don't have any therapy attached to them as say 90805s) but rather, will rely solely on E&Ms for medication management now that 90862s are gone. All of the APA Coding FAQs and documents explain that time-based coding MAY be used with an E&M code in lieu of complexity coding but ONLY if 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.

So my question is. It seems like coding by time is less complex than standard E&M coding. If our psychiatrists tend to spend a lot of time COUNSELING about the above sort of things (NOT PSYCHOTHERAPY), what is the downside to coding by time?