Gastroenterology Coding Alert

Worried about "double dipping" for ROS and HPI? Fear not, this rep. says.

Coders face this issue every day: You'll get some E/M guidance from a colleague, then hear conflicting advice at a conference, and get even different information from a consultant. When will you know which E/M directives are legitimate? The best answer is to go straight to the CMS website or to your MAC.

One Part B MAC, Novitas Solutions, recently made its E/M guidance public during the Nov. 2 teleconference, "New Patient Guidelines and Coding." Read on to discover five realities that will make you think again about some commonly-held E/M myths you may have believed.

Myth 1: Thick Documentation Leads to A High-Level Code

Many coders have written to the Coding Alert with this issue: Their physicians will produce a high level of documentation, leading the doctors to automatically select a level-five E/M code. However, that won't always work.

Medical necessity is "the overarching criteria for payment in addition to the individual requirements of CPT^®," said Novitas' Serena Hempkins during the webinar. "The volume of documentation should not be the primary influence on the level of service billed," shesaid. "Documentation should support the level of service reported."

Therefore, the next time your physician hands you a thick chart with a high service level circled but you don't see documentation to support that code, sit down with him and go over the elements in the record. Once the physician sees the specific requirements for reporting the high-level E/M codes, he may be able to accurately select the right code the next time. The nature of the presenting problem and complexity of medical decision-making are actually the key aspects of a note that an auditor will review.

Myth 2: Surgical Visits Don't Count Toward "New Patient" Rules

As most practices aware aware, CPT^® clearly defines what qualifies as an established patient: "An established patient is one who has received professional services from the physician/qualified healthcare professional or another physician/qualified healthcare professional of the exact same specialty and subspecialty who belongsto the same group practice, within the past threeyears."

Many practices take this to mean that if a patient has never had an E/M visit at the practice before, then he is automatically considered a new patient, but there are some types of face-to-face services that fall outside of that. In fact, if a surgeon operates on a patient in the hospital and then sees her a year later at his practice, that patient would be considered established, even if they never spoke or had an E/M encounter before.

"Surgical procedures require a face-to-face encounter between the physician and the patient," Hempkins said. "A patient is not considered new if a surgical procedure is performed and billed within the preceding three years by the same physician or a physician from the same specialty in that same group practice."

This means that if a screening colonoscopy was performed in a "direct access" program (no prior E/M evaluation), and then the patient is seen two and a half years later about a complex problem, the patient is still "established" for purposes of the E/M code selection. The exception would be if a payer recognizes consul­tation codes and if the circumstances qualify for use of consultation codes.

If, however, the doctor simply interpreted a radiological or lab test for the patient but never saw her face-to-face, in that case you should qualify for a new patient visit, Hempkins said.

Know where NPPs stand: Visits with non-physician practitioners (NPPs) count toward the three-year rule, Hempkins added. "NPPs assume the specialty of their group practice and a new patient visit by an NPP counts as a new patient visit for all practitioners of that group practice," she advised. The same consideration pertains for a locum tenens coverage, or on-call coverage.

Myth 3: Switching Practices Restarts the 3-Year Rule

Suppose a physician joins a new group practice and brings along some patients from her previous practice, whom she has seen within the last three years.

Although the new group practice has never seen these patients before, the patients are still considered established, said Novitas' Tasha Bishop. "Remember, once established to one physician, then established to all physicians in the same group with the same specialty," she advised. "The physician brings the status of the patient with them to the new practice." Keep in mind that not all payers would agree with this opinion, at least in the case where new records need to be set up and particularly if old records are not available.

Myth 4: You Can't Count One Element Toward Both HPI and ROS

Although the myth has persisted for years, most payers don't agree that practices are barred from using one documented statement toward both the review of systems (ROS) and the history of present illness (HPI).

"It's not considered double-dipping to use the systems addressed in the HPI for credit in the ROS, because review of systems inquiries are questions concerning the systems directly related to the problem identified in the HPI," Hempkins said. "So you can receive credit in two places with a single statement."

For example, if a patient presents with abdominal pain, you can credit that toward "location" in the HPI and toward "gastrointestinal" in the review of systems.

Myth 5: Documenting "Abnormal" By Itself Is Sufficient in the Exam

When documenting the exam portion of the E/M service the physician can write that a particular system is "normal" when warranted. "However, if the documentation says 'abnormal,' there must be further documentation as to why the exam is abnormal," Hempkins said.