EM Coding Alert

Level of care should be determined by elements and rise with time.

"According to an Office of Inspector General (OIG) report, billing of lower level emergency department codes is declining while billing of higher level codes is increasing. The OIG determined that from 2001 to 2010, 'Physicians' billing of the highest-level code (99285) rose 21 percent, increasing from 27 to 48 percent.'"

So, said Part B Medicare Administrative Contractor (MAC) Palmetto GBA in its Comparative Billing Report (CBR) released Nov. 6, 2017.

Has your emergency department (ED) been guilty of adding to these inflated claims? Want to find out if you're billing 99285 (Emergency department visit for the evaluation and management of a patient...) correctly? Read on and see if 99285 is really the way to go.

1. Know the Elements

To report 99285, CPT^® indicates, "usually, the presenting problem(s) are of high severity and pose an immediate significant threat to life or physiologic function." But that isn't all you need – the documentation must also support a comprehensive history, a comprehensive exam, and high-complexity medical decision-making.

To achieve the comprehensive history, the physician should document 10 or more systems in the Review of Systems (ROS), four history of present illness (HPI) elements, and two of the three past, family, and social history (PFSH) elements. For a comprehensive exam, the physician must document the eight or more organ systems that were examined (including the affected area). In addition, the physician must calculate medical decision-making of high complexity.

Therefore, you might consider memorizing the following numbers for 99285 requirements:

2. MDM Is Not Enough

EDs often report that their physicians will tally up very high levels of medical decision making (MDM), leading them to select 99285. However, E/M services in the ED require you to document and meet all three requirements - history, exam, and MDM - to meet each level of E/M service. This is different from outpatient E/M codes, which require you to meet only two of the three levels for established patients. So, a high-complexity MDM is necessary for reporting 99285, but not on its own. You still need the comprehensive history and exam clearly documented in the record.

For instance: Suppose a patient comes to the ED complaining of pain in the left side of his head, nausea, and weakness. The ED physician orders a CT scan and performs a lumbar puncture to rule out a subarachnoid bleed, and the documentation reveals four HPI elements, six ROS, two PFSH, and eight organ systems examined. Because of the conscious sedation for the lumbar puncture, the MDM supports a risk of level five.

In this case, the chart does not meet the criteria for 99285, because the ROS falls short of the 10 elements required for a comprehensive history. Instead, the six-element ROS supports only a detailed history, which bumps the correct code level down to a 99284.

Don't forget the acuity caveat: If, for some reason, the patient's condition prevents the physician from performing a complete ROS, the reason should be in the documentation, which could allow the practice to report 99285 under the ED acuity caveat rule, which allows you to document the history and physical exam that is reasonably obtainable from a severely ill patient, thus letting you move past this requirement when all other elements support a 99285. However, if you use this rule, your documentation must clearly state why the physician was unable to obtain a complete ROS.

3. Know When Critical Care Usurps 99285

In some cases, ED physicians will report 99285, even when the documentation would be better suited for a critical care code. Because critical care codes reimburse at a higher level than the ED codes, you could be throwing money away if you are unable to recognize the difference between a 99285 and a critical care service.

For instance: The local emergency medical service brings a motorcycle accident patient to the ED, and the ED physician diagnoses the patient with a femoral shaft fracture of the left leg. Additionally, the patient's distal left foot appears dusky and cool to the touch. Distal pulses are not palpable. The ED physician splints the entire extremity, places a Foley catheter to monitor urine output, and starts an IV to maintain cardiac output and minimize the likelihood of shock. He contacts a specialty hospital, which accepts the patient in transfer but advises that the ambulance will take 60 minutes to arrive. During the 60-minute interval, the ED physician spends 30 minutes in and out of the patient's cubicle checking for pulses, adjusting the splint, and monitoring cardiac output. However, the time spent attending to the patient, including initial evaluation, review of the patient's x-rays, discussion of the case with the receiving trauma surgeon, and follow-up of the patient's condition, totals 60 minutes. This excludes time spent placing or adjusting the splint, which is billed separately.

This service meets the critical care requirement of direct delivery by a physician of medical care for a critically illor injured patient, and you should report 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes) as well as the code for the long leg splinting (29505). Append modifier 25 (Significant, separately identifiable evaluation and management service by the same physician or other qualified health care professional on the same day of the procedure or other service) to 99291 to designate it as separately identifiable from the splinting.