I will throw my two cents into the discussion...

Karen is correct, you absolutely do not want to select the same E/M code for everyone, especially a high level one like a 99214. That is like sending an engraved invitation to the OIG to come audit the doctor/practice.

While E/M codes can be selected based on time alone, that is the exception, not the rule. And as Karen also said, the complexity factor comes into play. The overarching criterion for selecting an E/M code is based on medical necessity. Medicare puts this right into their E/M manual for providers:

"Medical necessity of a service is the overarching criterion for payment in addition to the individual requirements of a CPT code".

So just because the time factor may be enough for a 99214, the medical necessity has to be there also.