ED Coding and Reimbursement Alert

Question: Does the ED physician need to complete all the HPI, ROS, history, and exam elements in order to bill for critical care time?


New Mexico Subscriber


Answer: No, he doesn't. You can bill critical care codes 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes) and +99292 (... each additional 30 minutes [list separately in addition to code for primary service]) without the elements that are required for general emergency department E/M codes.

Unlike the emergency department E/M codes (99281-99285), with which the documentation needs to satisfy either CPT or Medicare requirements, the rules are less stringent for critical care codes. Though the patient's chart should certainly reflect the nature of his condition and the clinical course the physician chose, there is no specific requirement regarding history of present illness (HPI) and review of systems (ROS) elements for critical care.

Codes 99291-99292 are time-based. The most important elements to look for in the physician's documentation: that the patient satisfies the definition of critically ill, and that the doctor delivered 30 or more minutes of critical care.

Remember: Don't include any time the doctor spent on separately billable procedures in the critical care minutes.