Time or MDM: How Should You Level a Progress Note?
Either, since the 2023 CPT E/M changes. Pick the one your note supports better. A 99233 requires high-complexity decision making or 50 minutes of total time on the date of the encounter.

What changed in 2023?
The AMA extended the office-visit rules to hospital and observation visits: level by medical decision making or by total time on the date of the encounter (AMA, CPT E/M guidelines, 2023). History and exam no longer set the level.
When does time fit better?
When the day was long and the decisions were not complex. Forty minutes with a family on goals of care can fall under the 50 minutes the 2026 CMS file lists for 99233, and that note may be a 99232 by time (CMS PFS relative value file, 2026). Count only your own time, on that date, and write the total.

When does MDM fit better?
When the thinking carried the visit: a new acute kidney injury, two drugs adjusted, a decision about escalation. Document the problems, the data you reviewed and the risk. The code follows the documentation and medical necessity, never the reverse.
The work RVUs each level carries are in the complete wRVU guide, and the gap between documented and credited work is in why your wRVU report doesn't match your notes. Questions? The Founding Member page has pricing details.


