ED Coding and Reimbursement Alert

Reader Question:

Conscious Sedation by Residents

Question: Can a resident perform conscious sedation (99141)? Does the teaching physician need to be present for the whole procedure or can he just monitor the resident?

New York Subscriber

Answer: For Medicare patients, the teaching physician rules state that the attending physician must be present during the entire procedure for a minor procedure (defined as less than five minutes) and during key elements of the procedure for a major procedure.

Conscious sedation would likely take longer than five minutes and would be characterized as a major procedure. Suture removal, on the other hand, is an example of a minor procedure.

From a clinical perspective, all phases of the administration of conscious sedation are key. Certainly the initial administration of the drugs is a period of heightened monitoring; once the procedure is completed and the patient begins to wake, the physicians may relax a little, but all phases of conscious sedation appear to be key. So, applying the TP rules suggests that the attending would have to be present for the entire procedure. In the end, the point may be moot as the teaching physician rules are Medicare's and Medicare does not pay for conscious sedation.

Reader Questions and You Be the Coder were reviewed by Michael Granovsky, MD, CPC, chief financial officer of Greater Washington Emergency Physicians in suburban Maryland.