ED Coding and Reimbursement Alert

Question: A private physician calls the ED physician to tell her a patient is coming in who needs medication X. The patient registers and receives meds from the nurse. The ED physician never sees the patient, and the patient receives no nursing assessment. We bill for the drugs, but Patient Financial Services writes off the cost because they can't submit a bill just for drugs (without a license). How should we really handle this?


Wisconsin Subscriber
 

Answer: This practice sounds fishy for multiple reasons. For starters, the ED physician is risking his license because patients are receiving medication with no examination. If the patient were to have a resulting problem and sue the physician, the doctor wouldn't have a credible defense.

Lawsuits are already pending against ED physicians who failed to examine a patient in a case like this. In one case, a private physician sent a patient to the ED for a shot of meperidine for a migraine headache. The patient suffered a subarachnoid hemorrhage after the ED visit.

Second, questions of facility licensure are rife in the situation you describe. For example, is the hospital licensed as a dispensing pharmacy? Is the nurse a licensed pharmacist? Did the patient receive medication in compliance with the state board of pharmacy's dispensing regulations--including lot number, expiration date, name of the medication, directions for use, and documented counseling?

The answer to these questions is probably no, which will invite the scrutiny of your state board of pharmacy, if no one else. You should discontinue this practice immediately for the safety of the patients and the careers of your staff

And this practice also carries the risk of violating EMTALA (Emergency Medical Treatment and Labor Act) rules, because the patient did not receive a medical screening exam.