# 99291/99292 2 physicians, same practice



## adi (Sep 3, 2008)

Look for clarification, please advice how your practice handles scenario below.  Thanks in advance - adiaz

Can you please help me clarify latest Critical Care - Med Learn article, especially page 9 of 15, last bullet and page 10 of 15 top bullet and example a) -    http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM5993.pdf


Dr. X and Dr. Y are in the same pulmonary practice and see the same pt
on the same day - 

Dr. X renders initial Critical Care, documentation supports - 99291,
total time documented = 40 minutes. 
Later on the same day, Dr. Y is called to see patient and renders
Critical Care services, documents 70 minutes.
Total Critical Care time for day = 110 minutes

According to MedLearn article, how should service be billed since
physician X and Y are in the same practice?

A) Dr. X will receive credit for total CC time (110) rendered for
day = 99291 x 1 and 99292 x 2

B) Dr. X will receive credit for 40 minutes = 99291 and 
Dr. Y will receive credit for 70 minutes = 99292 x 2

If option B is submitted, will an edit be generated due to code 99292
being an "add on" code only that requires code 99291 to be submitted.


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## ARCPC9491 (Sep 3, 2008)

Physicians of the same specialty within the same group practice bill and are paid as though they were a single physician.  The answer is A - Dr. X gets credit for the total CC time.


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## adi (Sep 3, 2008)

I have added recent MedLearn article on Critical Care.   Previously I have been given credit to 1 physician, but after reading article, I am now questioning if correct.  adiaz


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## ARCPC9491 (Sep 3, 2008)

Answer B would be if it were two different specialities and not duplicate services. 

The initial CC time, 99291, must be met by a single physician. This may be performed in a single period of time or cumulative by the same physician on same calender date.  Subsequent CC, 99292, must be met by a single physician or physicians in the same group practice within the same medical specialty in order to meet the duration of minutes required for 99292.  Physicians in the same group practice who have the same specialty may not each report 99291 for CC to the same patient on the same calender date.  Same specialty, same group, CC is billed as though each were the single physician (Ref to Medicare Claims Processing Manual, Pub 100-04, Chapter 12 and 30.6)

Physicians in the same group practice who have different specialties may bill and be paid without regard to group membership.


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## FTessaBartels (Sep 3, 2008)

*I see your point*

Well, adiaz, having read the article you attached, I see your point. This article *clearly *states that if you have two physicians in the same practice, with the same specialty then only ONE bills 99291, and any subsequent critical care visits on the same date of service are billed using 99292.  Of course, the documentation must show that two (or more) visits were medically necessary. *NOTE* first MD must have at least 30 minutes critical care time, because s/he has to meet the 99291 criteria by him/herself.

The article does go on to say (pg 10 in the example of the two pulmonary physicians)  "... _and the second, as part of the same group practice, would report CPT code 99292 on the same calendar date *if the appropriate time requirements are met*." _(emphasis added by FTB)

So, this means that if Dr X spent 40 minutes (99291) and later in the day Dr Y spent 30 minutes, you would only bill 99291 to Dr X (because you need a total of 75 minutes to bill 99292 - and if all this time was provided by one doctor, he would not get to bill the add-on code (needs 75 minutes)

And in your example, adiaz, answer B is correct.

*Bear in mind* ... this article is *specific to CMS *... the AMA writes/owns the CPT and may or may not agree with CMS interpretation. Other carriers may not agree either. 

GREAT question!  Really woke up the brain cells on this one.
F Tessa Bartels, CPC, CPC-E/M


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## adi (Sep 4, 2008)

Thanks for the responses.  I appreciate your feedback.  adiaz


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