Does ‘shall’ mean ‘must’? In law, maybe – but not in CMS, CPT manuals
Question: A lawyer told us that when “shall” appears in official guidance, it means “must.” For example, because the CPT manual says that when counseling and/or coordination of care is more than 50% of an encounter, “time shall be considered the key or controlling factor to qualify for a particular level of E/M services….” He says that means we have to bill based on time for those encounters. Is he right?
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