Inpatient Facility Coding & Compliance Alert

Question: Some of my physicians are stuck on the “teaching” exclusion of the critical care definition. I’ve tried to tell them that the initial presentation by the resident and going over the case and discussing the tests ordered is not teaching. Any other instruction you could offer would be great. Has anyone ever defined what teaching is?

Michigan Subscriber

Answer: CMS Transmittal 1548 does state that in Section E.5, under Inappropriate Use of Time for Payment of Critical Care Services, that “time involved in activities that do not directly contribute to the treatment of the critically ill or injured patient may not be counted towards the critical care time, even when they are performed in the critical care unit at a patient’s bedside (e.g., review of literature, and teaching sessions with physician residents whether conducted on hospital rounds or in other venues).”

In Section M of that same transmittal, it goes on to say that “Time spent teaching may not be counted towards critical care time. Time spent by the resident, in the absence of the teaching physician, cannot be billed by the teaching physician as critical care or other time-based services. Only time spent by the resident and teaching physician together with the patient or the teaching physician alone with the patient can be counted toward critical care time.”

Time spent in teaching is above and beyond the provision of critical care to the patient. It does not mean that any critical care event that might involve a resident or student does not count.