Cardiology Coding Alert

Question: Can a cardiologist bill 99282 if the service is rendered in the emergency department (ED)?

Oregon Subscriber  
Answer: The short answer is yes, says Terry Fletcher, BS, CPC, CCS-P, a cardiology coding and reimbursement specialist in Laguna Beach, Calif. But the ED visit codes may not best describe the encounter.
 
Often other E/M codes may be more appropriate, including inpatient admission (99221-99223), admission to observation (99218-99220), outpatient consultation (99241-99245), critical care (99291-99292) and new (99201-99205) and established patient (99211-99215) visit codes.
 
Medicare national policy (Medicare Carriers Manual [MCM], section 15507) instructs physicians to use ED codes even if an emergency-room physician also bills for the same service. The ED guidelines also state:
 
These codes should be paid regardless of whether the physician is assigned to the emergency department.
 
Any physician seeing a patient registered in the emergency department may use these codes.
 
ED codes should be used only if the patient is seen in the emergency department.
 
ED codes should be paid regardless of whether the services were "emergency services," as long as the patient was seen in the ED. A lower-level ED code should be reported for nonemergency conditions. 
 
Cardiologists should not bill using 99281-99285 if:
 
The patient is admitted by the cardiologist to the hospital or to observation on the same calendar date, in which case initial hospital care or admit-to-observation codes should be used.
 
The encounter meets the criteria for a consult or for critical care services.
 
The patient is not registered at the ED, even though he or she met the cardiologist there. In such cases, an outpatient visit code should be reported, with 23 (for ED) listed as the place of service.
 
Although the guidelines are clear, many carriers, private and Medicare alike, continue to accept only one ED bill per patient per day, regardless of how many physicians see the patient in the emergency room. An ED visit that cannot be coded as a consultation, admission/observation or critical care service should be reported using outpatient visit codes, listing 23 (for ED) as place of service.
 
Often, the cardiologist's ED encounter may be correctly billed as a consultation. Some cardiologists, however, routinely bill consults when they see a patient in the ED. This is incorrect, Fletcher says, noting that according to the MCM, "If the emergency department physician requests that another physician evaluate a given patient, the other physician should bill a consultation if the criteria for consultation are met" [emphasis added].
 
The three criteria for a consultation are stated in the MCM, section 15506:
 
1. A consultation is distinguished from a visit because it is provided by a physician whose opinion or advice regarding evaluation and/or management of a specific problem is requested by another physician or other appropriate choice.
 
2. A [...]