Inpatient Facility Coding & Compliance Alert

Question: One of our ED physicians removed nasal packs that another doctor at our hospital placed for the patient. The two physicians belong to the same ED group. Is there a code for the nasal pack removal? It’s not a foreign body, so I am unsure. I think removal is part of the initial service, which would mean the physician who puts in the nasal packing cannot bill for the removal. But what about this situation when we’re talking about different doctors?

Florida Subscriber

Answer: In the scenario where a patient comes in for follow up on a global code and you did not perform the original service, an E/M code is usually the best way to report that follow up service. If the packing was placed by the same ED group then it would likely fall into the construct of typical post-operative care. Keep in mind that depending on the initial procedure (such as treatment for epistaxis) there could be a 0 day global period. If there is a 0 day post-operative period, then subsequent services on a later date of service are separately coded and billed. So check your initial service and make sure you are outside of the global period and it is not part of typical care.

Note: This situation differs relative to the outpatient side with APCs. For APCs, there are no pre-operative or post-operative days as such, so coding and billing are on an encounter basis. In the scenario above, it is possible that there should be no billing for the later date on the professional side. However, there will still be a facility component for this later service because there is a new encounter.

There is a further complication in that ER physicians are not required to use the -54 modifier indicating intra-operative services only. That is, ER physicians are paid for the global package even if another physician (outside the ER group) provides the subsequent services (e.g., suture removal.)