Neurology & Pain Management Coding Alert

Question: A patient whom I admitted to a skilled nursing facility in January died in June. The facility required that I, as the admitting physician, had to perform a discharge summary and sign the death certificate. How do I bill for this? Is there a specific discharge code to use?

Wyoming Subscriber

Answer: Patricia Niccoli, president of ElectroAge Billing, a medical billing firm in Phoenix, relays the following from section 50-19 of the Medicare Coverage Issues Manual: According to established legal principles, an individual is not considered deceased until there has been official pronouncement of death. An individual is therefore considered to have expired as of the time he/she is pronounced dead by a person who is legally authorized to make such a pronouncement, usually a physician. Reasonable and necessary medical services rendered up to and including pronouncement of death by a physician are covered diagnostic or therapeutic services.

The manual does not offer any advice on what codes should be used for pronouncement of death, but depending on your insurers rules, you may be able to use the nursing facility discharge codes (99315, 99316). Some carriers allow caregivers to bill these codes when any of the discharge criteria are met (in this case, you would be preparing the discharge records, which would meet one criteria of the discharge). Most carriers believe that all of the discharge criteria must be met. In your case, they would not be met because the criteria include discussing the patients care with him or her and with future nurses or caregivers.

If you are responsible for conducting the pronouncement of death, some carriers may allow you to bill 99311 (subsequent nursing facility care, per day, for the evaluation and management of a new or established patient, which requires at least two of the following three key components: a problem focused interval history; a problem focused examination; medical decision making that is straightforward or of low complexity) for your examination and the pronouncement. If you are simply filling out a discharge summary and finalizing the patients paperwork, you could bill 99080 (special reports such as insurance forms, more than the information conveyed in the usual medical communications or standard reporting form). If your insurer does not allow any of these codes for your service, you may have to revert to 99199 (unlisted special service, procedure or report).