Medicare Compliance & Reimbursement

Tip: Go by the book.

The teaching physician section in the Centers for Medicare and Medicaid Services (CMS) critical care Transmittal 1548 from July 2008 has specific language relating to the requirements for how teaching physicians report critical care services, says Michael A. Granovsky, MD, FACEP, CPC, President of Logix Health, a national ED coding and billing company based in Bedford, MA. This transmittal seems to hold the teaching physician’s documentation of critical care to a specific standard and set of time counting criteria.

“For CPT^® codes determined on the basis of time, such as critical care, the teaching physician must be present for the entire period of time for which the claim is submitted,” CMS advised in the transmittal.

Section M of Transmittal 1548 goes on to state “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.”

Example: CMS provides the following example of acceptable teaching physician documentation. “Patient developed hypotension and hypoxia; I spent 45 minutes while the patient was in this condition, providing fluids, pressor drugs, and oxygen. I reviewed the resident’s documentation and I agree with the resident’s assessment and plan of care.”

Vital: Remember that a resident’s work and time providing critical care services cannot be used by the teaching physician to support reporting critical care.