Medicare Compliance & Reimbursement

It's a common occurrence: The emergency room physician evaluates a patient by performing a complete E/M service, and then determines that the patient requires critical care services, which are administered. However, the days of billing both an emergency department E/M code and a critical care code will soon be gone forever.

On Oct. 1, the Correct Coding Initiative (CCI) started bundling the ED visit codes (99281-99285) into critical care codes (99291-99292) and no modifier can separate the edits. Although the CCI has bundled these codes together for over a decade, the fact that the bundle indicator changed from "1" to "0" on Oct. 1 is new.

Most coders have already eliminated the practice of reporting both an ED code and a critical care code on the same date, because Medicare stopped paying for both concurrently in 2008.

"Hospital emergency department services are not payable for the same calendar date as critical care services when provided by the same physician to the same patient," CMS said in Transmittal 1548, dated July 9, 2008.

Therefore, be sure to report only the appropriate critical care service and not the ED E/M code when the same physician or another practitioner from the same group practice performs the services.