Inpatient Facility Coding & Compliance Alert

Question: Where do Coumadin and amiodarone fall in the E/M medical decision making Table of Risk?

South Carolina Subscriber

Answer: Amiodarone, which treats life threatening arrhythmias, meets the requirement for intensive monitoring of toxicity under the E/M Table of Risk’s high complexity listing. Patients on amiodarone have regular visits to check for toxicity in various organ systems.

There’s less consensus on Coumadin. Many experts advise considering Coumadin to qualify for the prescription drug management that falls under moderate complexity.

However, many physicians feel that the wide range of considerations involved in treating a patient on the anticoagulant Coumadin fall under the high complexity category.

Check this out: Part B MAC Palmetto has published a statement that Coumadin is high risk: “Coumadin (any setting) and Heparin (hospital setting only) are considered ‘high risk’ (‘Drug Therapy Requiring Intensive Monitoring for Toxicity’). To consider therapy with one of these drugs as a high risk management option, we would expect to see documentation in the medical record of drug levels obtained at appropriate intervals” (www.palmettogba.com/palmetto/providers.nsf/DocsCat/Jurisdiction-11-Part-B~96KS860514).

Caution: The Table of Risk is a guide, not an absolute. You should base the assessment of risk on the documentation for the specific patient encounter. You can view a Table of Risk on page 20 of Medicare’s “Evaluation and Management Services Guide” (www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/eval_mgmt_serv_guide-ICN006764.pdf).