Medicare Compliance & Reimbursement

Question: How is physician time measured for the purpose of reporting critical care?

Answer: The duration of critical care services for both CPT^® and Medicare is based on the physician’s documentation of total time spent evaluating, managing, and providing care to the critical patient, as well as time spent in documenting such activities. The physician must devote full attention and be immediately available to the particular patient for every minute of time claimed. This time may be spent at the patient’s immediate bedside or elsewhere on the unit, as long as the physician is immediately available to the critically ill or injured patient, says Michael A. Granovsky, MD, FACEP, CPC, President of Logix Health, a national ED coding and billing company based in Bedford, MA.

For example: Time spent can be at the bedside, reviewing test results, discussing the case with staff, documenting the medical record, and time spent with family members (or surrogate decision makers) discussing specific treatment issues when the patient is unable or clinically incompetent to participate in providing history or making management decisions.

Take note: When the provider performs separately reportable procedures or services, you cannot count that time as part of the total time you report as critical care time. You also can’t count time involved in activities like restocking of supplies that do not directly contribute to the treatment of the critical patient toward the critical care time.

The critical care codes 99291 and 99292 are used to report the total duration of time spent by a physician providing critical care services, even if the time spent by the physician on that date is not continuous.

You can aggregate non-continuous time for critical care services for a single date. Use CPT^® code 99291 to report the first 30-74 minutes of critical care on a given date. This code should be used only once per date. Use code 99292 to report additional block(s) of time of up to 30 minutes each beyond the first 74 minutes of critical care.

Don’t do this: Don’t use the critical care codes to report critical care time of less than 30 minutes. Instead, report such service the appropriate E/M code, like 99285 (Emergency department visit for the evaluation and management of a patient, which requires these 3 key components within the constraints imposed by the urgency of the patient’s clinical condition and/or mental status … ) based on the nature of the presenting problem documented, states Granovsky.