Cardiology Coding Alert

GAO's correct and complete response leaves out 4 factors The question of how to code a physician transferring a patient from one hospital to another seems simple, but the answer is more involved than you may think.

The Government Accountability Office (GAO) asked CMS call centers this very question and found that 96 percent of the time, the CMS call centers' answers were inaccurate, only partially correct, or totally incomplete.

However, even the GAO's correct responses leave cardiology coders with something to be desired.

The GAO asked: How should you code a physician transferring a patient from one hospital to another?

What the GAO counted as the correct and complete response: "Physicians may bill both the hospital discharge management code and an initial hospital care code when the discharge and admission do not occur on the same day if the transfer is between (1) different hospitals, (2) different facilities under common ownership which do not have merged records, and (3) between the acute care hospital and a PPS-exempt unit with the same hospital when there are no merged records. In all other transfer circumstances, the physician should bill only the appropriate level of subsequent hospital care for the date of transfer."

What's left out: CMS' response mentions nothing about transfers between physicians in the same group practice, hospital care versus consult codes, or place of service. Nor does this response take into account discharges performed by a nonphysician practitioner (NPP) or physician assistant (PA). 1. Group Practice Member Changes Rules Cardiologists may transfer a patient to another member of their group practice.

According to the Medicare Carriers Manual (MCM), section 15501.1, if a patient undergoes more than one E/M service on the same day by more than one physician in the same group, then "only one E/M service may be reported unless the E/Ms are for unrelated problems." In this scenario, both cardiologists would select the combined E/M level and submit the appropriate code.

Note: If the second physician belongs to the same group practice but is of a different specialty (for example, an internal-medicine specialist transfers the patient to a cardiologist), you should report the E/M codes separately. 2. Cardiologists May Share Visit With NPP The CPT manual's introduction to codes 99238-99239 says that these "codes are to be used to report the total duration of time spent by a physician for final hospital discharge" - but does that include work provided by nonphysician practitioners?

The term "physician," with regard to E/M services, entails NPPs when they provide services within their scope of practice, licensure, collaboration rules and billing rules for Medicare, says a CMS official. This means that NPPs may report the codes for "hospital discharge, management," and for "initial hospital care." [...]