ED Coding and Reimbursement Alert

Medicare states that the EKG interpretative report must be a complete written report similar to that usually prepared by a specialist in the field and should be consistent with the service furnished.

Medicare policy also states an "interpretation and report" should address the current findings, relevant clinical issues, and comparative data when available.

Discern Review from Interpreted Report

A chart notation of "EKG normal" is deemed an insufficient interpretation and report and would be considered a "review" rather than an interpretive report. This is the type of "review" that would be included as part of the "Amount and Complexity of Data Reviewed" element of Medical Decision Making, says Caral Edelberg, CPC, CPMA, CAC, CCS-P, CHC, President of Edelberg Compliance Associates in Baton Rouge, Louisiana

Although individual payers may develop their own standards, some Medicare carriers follow the requirement that an EKG interpretation should include at least 3 of the following 7 elements:

• Rhythm
• Rate
• Axis
• Intervals
• ST Segment Change
• Comparison to a prior EKG
• Summary of clinical condition

Medicare does not require that the ECG interpretation be recorded on a separate piece of paper; rather a complete written interpretation can be recorded within the emergency department treatment records. However, some Medicare carriers have independently established more restrictive criteria.

Follow These Documentation Tips

To qualify as separately identifiable, consider chart documentation similar to a procedure note or include a separate area on a templated documentation form for EKG interpretation. Be sure it clearly identifies who is providing the interpretation, particularly when more than one provider (MD, PA or RNP) or residents are involved in the treatment of the patient.

When residents do the interpreting: Providers should be aware of the requirements that Medicare applies to resident physicians interpreting diagnostic studies: "If a resident prepares and signs the interpretation, the teaching physician must indicate that he/she has personally reviewed the image and the resident's interpretation and either agrees with it or edits the findings. Medicare does not pay for an interpretation if the teaching physician only countersigns the resident's interpretation." states CMS Transmittal 2303, released Sept. 14, 2011.

While EKGs are not specifically mentioned in the transmittal, individual carriers may extrapolate this language to include EKGs. Many of the individual carrier policies simply echo national CMS policy as to what should be included in an interpretation and report, but some carriers have developed their own specific documentation requirements for EKG interpretations. You should check the Local Coverage Decision (LCD) for your state to be sure you are in compliance with your carrier.