Coding and Reimbursement Pearls
The below documentation, reimbursement and coding topics are designed to be short articles that are suitable for publication in your groups newsletter or email notifications.
Behavior Modification Counseling (Top)
Behavior Modification codes are available for tobacco use (CPT® 99406-99407) counseling; alcohol and/or substance abuse structured screening and brief intervention (CPT® 99408-99409, Medicare G0396-G0397). These services are time-based and may be separately identifiable services in addition to Evaluation/Management services. Document face-to-face time spent counseling. Retain standard screening tool (e.g. AUDIT, DAST, T-ACE, SBI) in the medical record.
Last Updated 4/30/2015
Critical Care (Top)
Do you know how to use Critical Care codes (99291-99292)? Critical Care is defined as an illness or injury that acutely impairs one or more vital organ systems such that there is a high probability of imminent or life threatening deterioration in the patient's condition and that the failure to initiate these interventions on an urgent basis would likely result in sudden, clinically significant or life threatening deterioration in the patient's condition. This underused code set requires physician documentation of the time spent directly managing the unstable or potentially unstable patient. Time spent documenting, reviewing labs and radiographs, and speaking with medical staff also counts towards total critical care time. Time spent on separately billable procedures, like CPR (92950), doesn't. You must have provided at least 30 minutes of services to bill, and the "first hour" of critical care includes the first 74, not 60, minutes. Additional time increments over the initial 74 minutes are billed with 99292 for each additional 15-30 minute segment. Time must be clearly documented by the provider and does not need to be continuous.
Critical Care - Part Deux (Top)
While there are codes you may use in addition to critical care (99291 and 99292), CPT bundles certain separately identifiable services into the codes for critical care. The bundled codes are included in the list below:
- the interpretation of cardiac output measurements (CPT 93561, 93562)
- chest x-rays (CPT 71010, 71015, 71020)
- pulse oximetry (CPT 94760, 94761, 94762)
- blood gases, and information data stored in computers (CPT 99090)
- gastric intubation (CPT 43752, 91105)
- temporary transcutaneous pacing (CPT 92953)
- ventilatory management (CPT 94656, 94657, 94660, 94662)
- vascular access procedures (CPT 36000, 36410, 36415, 36540, 36600), these are peripheral access. Central access is not bundled.
Any procedures not on this list can be billed separately, and the time spent performing additionally billed procedures must be deducted from Critical Care time and indicated in the record. A statement such as "Critical care time spent in direct management of this patient was 75 minutes exclusive of separately billed procedures" it is recommended.
Electronic Medical Record (EMR)/Electronic Health Records (EHR) (Top)
The Electronic Medical Record (EMR) or Electronic Health Record (EHR) is here to stay. There are many different vendors. For emergency medicine, the big difference is whether your department opts for an enterprise system or a boutique system that is specifically designed for emergency medicine. The decision as to which type of EMR you should choose is typically made in conjunction with your hospital system. The challenge after choice is preparation and implementation to minimize care disruptions.
Key considerations to address during the preparation phase:
Understand and map typical pre EMR workflows for all members of the department team. This goes beyond clinical providers. Each provider group should have input in the development of their new workflow.
Managing and testing the reports/access to the EMR that your coding staff/billing company have is key to assuring that the coding transition goes smoothly. Do not assume if moving from paper to EMR that the coders easily have all information. These interfaces need to be built.
Most EMR companies have generic training modules, encourage the development of local "super users" or "Champions" who can alter and/or teach the EMR based on your department workflows.
Identify an on-site EMR specialist to serve as the liaison for the providers/users and the EMR vendor
Obtain comprehensive, quality training to support providers throughout the implementation process and beyond - in all but the smallest of institutions on-going system customization and training new staff as old ones turnover is a full time need
Make sure existing hospital/department electronic systems have supportable interfaces with the EMR
Require a comprehensive education and orientation to all providers including all end users prior to implementation
Visit departments who have recently implemented the EHR to discuss what worked and what didn't
Key considerations to address during the implementation phase:
- Extra staffing during implementation phase as throughput will be affected by the learning curve
- Make sure there is 24 hour support and troubleshooting team in the first month
- Assure that ED specifically trained support continues to be supported for updates and future changes
Emergency Department After-Hours Code (Top)
Tired of working night shifts? There is a code is available to report services provided in the ED after10 pm. Patients presenting to the ED between10 pm and 8 am may have code 99053 (After-Hours code) reported in addition to the standard 99281-99285 for emergency department levels of service. This code is not typically paid by governmental payers, but can result in modest additional payments from others.
FAST Exam (Top)
Focused Assessment with Sonography for Trauma (FAST) exam is an increasingly valuable tool for many EPs, but the documentation and coding requirements are often misunderstood. There is no single CPT code that captures the components of a typical FAST exam. Most FAST exams consist of two distinct US exams, limited cardiac (93308) and limited transabdominal (76705). Documentation should clearly reflect two separate and distinct exams. Some providers may also perform a limited chest US (76604) to evaluate for hemo/pneumothorax. Performance of the respective components of the FAST exam will of course depend upon the circumstances of the patient's clinical presentation/progression. Code for the components that were performed and documented.
Note that ultrasound CPT codes are “global” service codes, and combine the technical and professional component of the examination. The professional component is indicated by the -26 modifier, and includes interpretation of the ultrasound study with preparation of a separate signed written report.
A typical report for an US exam performed in the ED typically includes the following elements (and should be a part of the medical record):
- Date and time of study
- Name of patient
- Hospital ID (medical record) number of patient
- Indication for study (i.e. Blunt trauma, penetrating trauma, hypotension, abdominal pain)
- Name of the person(s) who performed the study
- Study finding(s), describing the organ/area studied
- Limitations and recommendations for additional studies
- Study impression
- Name of the person who interpreted the study
- Date and time the report was signed
Image archiving refers to the storage and retrieval of an ultrasound image. For billed studies, it is essential that ultrasound images be stored and archived for future review. Simply documenting FAST as "normal" or "negative" does not meet documentation requirements. For additional information, please reference the ACEP Ultrasound FAQs at the following link: www.acep.org/practres.aspx?id=30502
HAC and POA (Top)
Hospital Acquired Conditions (HAC) and Present On Admission (POA) are a pair of terms influencing hospital reimbursement for inpatients. Conditions occurring during an emergency department visit are considered POA Payers may reduce or eliminate inpatient reimbursement for a variety of hospital-acquired conditions that are not present on admission. Coders and reimbursement staff are querying physicians about conditions not clearly documented as present in the ED prior to admission.
ED physician documentation is crucial to support whether or not a condition was present at the point of hospital admission. Some key ED documentation opportunities include:
- Infections or complications of urinary catheters, dialysis ports and PICC lines;
- Infections of integumentary, genitourinary, respiratory systems;
- Staged decubitus ulcers;
- Context of injuries (e.g. falls);
- Adverse drug effects and reactions;
- Interpretation of abnormal lab values (e.g. blood glucose, PTT and electrolytes).
While the terms “rule out”, “suspected” and “probable” relating to conditions cannot be coded as established diagnoses for ED physician billing, recording of these differential diagnoses are valuable for the inpatient-coded record, which must capture these for inpatient diagnosis billing purposes. Your HPI, ROS, PMH and Clinical Impression documentation are more important than ever to support reimbursement for your hospital partner.
Hospital Observation Services – Technical Component (Top)
Emergency Medicine Revenue Source: Observation. Remember, Observation, or Extended Assessment and Management (EAM) as it is called for technical billing, is not a place, it is a status! If admission is a foregone conclusion, write for a full Admission, not Observation. The decision process is whether to Admit to inpatient status, place the patient in Outpatient Observation, or Discharge the patient home. Physician services for observation in the ED are billed in place of the ED visit code (99281-99285 or 99291), not in addition to them. When the hospital bills for the technical (hospital) portion of Observation generated from the ED, the hospital must bill an ED visit 99284, 99285 or Critical Care 99291 in order to have Observation recognized for payment. This is a major difference from the physician coding and billing policy which recognizes either Observation (99218-99220 or 99234-99236) or the ED Evaluation and Management Codes (99281-99285 or 99291).
In House Codes (Top)
Don’t lose revenue for inpatient codes, consults, critical care and emergent procedures. Establish a procedure to alert coding/billing staff for inpatient emergent services, ensure they can locate the inpatient encounter, and take the time to document your services. If the inpatient attending requested your expertise to assess a patient, be sure an official consult order is noted in the chart. Also note--consults require 3/3 past medical/family/social history elements for high acuity patients. Document total time spent during the patient encounter.
Laceration Repair (Top)
1. These valuable procedures are categorized by CPT® as Simple, Intermediate, or Complex. Remember that not all single layer repairs are automatically considered simple. If the wound is heavily contaminated and requires "extensive cleaning or removal of particulate matter" a single layer repair may be reported as Intermediate. Note the size, suture, staple and/or adhesive material used for each layer, and specific anatomical location for each laceration repair. This information guides the coders to identify the repair as simple, intermediate or complex.
2. Capture charges for re-checks and suture removal following simple laceration repair for patients covered by Medicare, and payers which follow Medicare payment policies. There is no global period for simple wound repairs (CPT® 12001-12018). Intermediate and complex laceration repairs have a 10-day global period for Medicare.
Level 5 Caveat (Top)
The definition of 99285 includes the concept that the History, Physical Exam, and Medical Decision Making (key requirements) must be met "within the constraints imposed by the urgency of the patient's clinical condition and/or mental status". This concept is called the emergency medicine caveat or the acuity caveat. Although the Medical Decision Making is referenced as one of the elements, the general consensus is that the caveat would apply to the History and Physical Examination. Most Medicare carriers require a description of the patient's urgent condition that prevents obtaining any of these key elements of the Evaluation and Management service as well as the physician's thought process through the discussion of risk factors, differential diagnoses, procedures, diagnostic studies, interventions and disposition. So make sure to document why the severity of your patient's illness and/or procedures such as intubation on arrival preclude or prevent performing a full History or Exam.
Updated Last 04/28/2015
Level of Service (Top)
Remember, you do not get reimbursed for what you do, you get paid for what you document about what you do! A frequent deficiency area for down coding a 99285 to a 99284 is the Review Of Systems (ROS). 99284 requires that you record a review of 2 - 9 systems with while 99285 requires the recording of ten or more. Listing of pertinent positives and/or negatives with the statement 'all other systems reviewed and negative' meets 99285 requirements. Also, remember to record your History of Present Illness (HPI) and Past, Family, and Social History (PFSH) as failure to document both appropriately can result in significant down-coding of your medically necessary services. For the HPI, 99284 and 99285 require documentation of four HPI elements. For the PFSH, 99284 requires recording of one of three PFSH elements and 99285 requires recording of two of three PFSH elements.
Medicare Resources (Top)
In the past several years, the Centers for Medicare and Medicaid Services (CMS) has published updates to coverage decisions through their MedLearn format. This information provides a reference for many topics relevant to emergency medicine.
With implementation of the new Medicare Administrative Contractors (MACs), many changes to the way you interact with Medicare will be taking place. The Medicare website is a valuable source of news and information regarding Medicare processes and changes in your specific practice location. Log on to their website for additional information. Click on the links below to find specific information regarding your contractor and any changes taking place.
*It is recommended that you insure your system is protected when opening any zip files.
Medicare's Teaching Physician Guidelines (Top)
Emergency Physicians, engaged in teaching interns, residents, fellows (IRF) and medical students as part of the attending's clinical practice, must satisfy unique requirements in order to qualify for reimbursement by Medicare. Specific rules govern the documentation of the history and physical exam, as well as any procedures that are performed.
Does this matter to me?
If you are a physician who sees patients with a medical student, intern, resident or fellow and you want to be paid, it does.
For Evaluation & Management (E/M) services, the teaching physician (TP) must be involved in the care of the patient by:
personally performing the entire service independently from an IRF; or
having the IRF render the service and discussing it with them, but also independently performing, at minimum, the "key portions" of the service; or
having the IRF render the service and discussing it with them, and also being directly present (i.e. in the same exam cubicle), at minimum, when the "key portions" of the service are performed by the IRF.
What can medical students do?
Medical students are limited to gathering certain aspects of History: Past, Family, Social History, and Review of Systems.
What must I document for a TP E/M?
At aminimum, you must personally document that you were physically present for or performed the "key portion" of the service and that you participated in the management of the patient.(Be sure to check the ACEP website for documentation examples minimally acceptable to Medicare.)
Your documentation must include a legible signature or an electronic signature that is password protected, and it must also include the date.
It is acceptable for a teaching physician to use an electronic medical record (EMR) macro (defined text phrase) to report his/her required personal documentation and should document any variances or corrections of the resident note.
What is the "key portion" of patient treatment?
This is defined by you, the teaching physician, but is susceptible to retrospective appraisal on audit. Determination of "key portion" should be based on the clinical aspects of the case (e.g. presentation, diagnosis, level of service, etc.) and the competency of the particular IRF.
What about time-based services such as Critical Care?
For the reporting of time-based services, such as critical care or moderate sedation, the teaching physician must be directly present during the entire reported time period. Additional teaching time performed during a critical care encounter cannot be added to the total critical care time. Both the TP and IRF cannot bill for simultaneous Critical Care time.
What about procedures?
For procedures taking longer than 5 minutes the Teaching Physician must be directly present for at least the "key portions".
If the procedure will take less than 5 minutes to perform, the Teaching Physician must be directly present for the entire procedure.
For additional information on Teaching Physicians, see the Teaching Physicians Frequently Asked Questions and the CMS policy transmittal on the ACEP website. http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c12.pdf
Moderate (Conscious) Sedation (Top)
Don't overlook sedation services provided by the ED physician solely or in support of another provider such as an orthopedist. Fill out your hospital conscious sedation forms and submit these to your coders to document the necessary information to bill for these services. Moderate Sedation codes include an initial code for the first 30 minutes of intra-service time, continuous time from meds given until your personal contact ends, (this code is fulfilled after 16 minutes is documented) and a code for every 15 minutes of intra-service time thereafter (fulfilled after 8 minutes). When calculating the total sedation time, be sure to only include the minutes involved in direct face-to-face monitoring of the patient, exclusive of separately identifiable evaluation and management prior to sedation and the time following the procedure performed (patient recovery).
Updated Last 04/29/2015
Observation Services- Physician (Top)
When lack of diagnostic certainty ( e.g. chest pain, head injury) or some additional therapeutic treatment (e.g. asthma) could prevent an inappropriate inpatient admission, consider Observation services. Observation is not a place, but an outpatient status and can occur in the Emergency Department by the ED Provider. Observation services require an order, "Admit to Observation", periodic progress note(s), and a brief discharge plan/summary. When disposition is uncertain, and estimated length of stay less than 48 hours, consider admit to OBS. For additional information on Observation, see the Frequently Asked Questions at: http://www.acep.org/Clinical---Practice-Management/Observation---Physician-Coding-FAQ/
Observation Discharge Services
When Observation status requires an overnight stay with two calendar dates of service, don't forget to document a brief discharge summary note the following day. Observation care discharge (CPT® 99217) is a separately billable service from Initial Observation (CPT® 99218-99220). Observation discharge services include a final exam, discussion of the observation stay, follow-up instructions, and preparation of discharge records.
Observation or ED E/M Levels?
If you are not sure whether it is worth the extra effort to document Observation services, consider this:
4.93 ED Comprehensive History, Exam, and High MDM
99220 + 99217
7.30 Initial Obs Day 1, Discharge Obs Day 2
6.15 Same Day Obs Admit/Discharge (min. 8 hours for Medicare)
Observation services need an Admit order, Admit note separate from the ED note, interval progress note(s), and a brief discharge summary. Remember that Observation codes 99219-99220 and 99235-99236 each require all three of past medical, family and social history for reporting Observation services.
Penetrating Wound Exploration (Top)
Don’t overlook a valuable set of CPT® codes (20100-20103) for penetrating wound exploration. Documentation of wounds requiring enlargement, extension of dissection (to determine penetration), debridement, removal of foreign body(s), ligation or coagulation of minor subcutaneous and/or muscular blood vessel(s) of the subcutaneous tissue, muscle fascia, and/or muscle should qualify for this hefty RVU code set. When thoracotomy with exploration (CPT® 32100) or laparotomy (CPT® 49000) are necessary, these codes are assigned instead of CPT® 20101, 20102.
Physical Exam (PE) Requirements (Top)
Electronic medical records should demonstrate patient-specific exam detail. 99285 requires a minimum of eight organ systems to be documented. If your exam note is organized by body areas (e.g. Head, Chest, Abdomen), make sure that organ systems (e.g. Eyes, ENT, Neuro, MS, Resp., GI, GU, CV, Integument) are identifiable in your PE documentation. Specify location of back and abdominal pain.