Ob-Gyn Coding Alert

The supervision designation moves from "9" to "1."

If you regularly report outpatient therapeutic services, then you need to make certain that your ob-gyn can meet the new general services requirements -- before you submit your claim.

Definition: General supervision means the procedure is furnished under the physician's overall direction and control, but the physician's presence is not required during the performance of the procedure, explains Marvel J Hammer, RN, CPC, CCS-P, PCS, ACS-PM, CHCO, with MJH Consulting in Denver, Colo.

Effective July 1, these services may be conducted under general supervision in accordance with applicable Medicare regulations and policies:

• 51701 -- Insertion of non-indwelling bladder catheter (e.g., straight catheterization for residual urine)
• 90471 -- Immunization administration (includes percutaneous, intradermal, subcutaneous, or intramuscular injections); 1 vaccine (single or combination vaccine/toxoid)
• 90472 -- Immunization administration (includes percutaneous, intradermal, subcutaneous, or intramuscular injections); each additional vaccine (single or combination vaccine/toxoid) (list separately in addition to code for primary procedure)
• 90473 -- Immunization administration by intranasal or oral route; 1 vaccine (single or combination vaccine/toxoid)
• 90474 -- Immunization administration by intranasal or oral route; each additional vaccine (single or combination vaccine/toxoid) (list separately in addition to code for primary procedure)
• 99406 -- Smoking and tobacco use cessation counseling visit; intermediate, greater than 3 minutes up to 10 minutes
• 99407 -- Smoking and tobacco use cessation counseling visit; intensive, greater than 10 minutes

History: Until now, none of these codes had been assigned a physician supervision level prior to July 1. Before, they had a designation of "09" which means "Concept does not apply."

What's new is that the CPT rule for physician presence (which applies to the IM injection code) never applied to vaccine administration. While CPT has a parenthetical note that states, "Physicians do not report 96372 for injections given without direct physician supervision. To report, use 99211," CPT has allowed you to bill the vaccine administration service even if the physician is not present to provide direct supervision.

Up until this change CMS did not have an opinion, but now CMS has made it clear that they expect general supervision, which is in keeping with the implied current CPT guideline for the vaccine administration.

Remember: The general supervision classification specifies that the following conditions must be met:

• The procedure is furnished under the physician's overall direction and control in the office setting.
• The physician's presence is not required during the performance of the procedure.
• The physician is responsible for ensuring that the nonphysician personnel who actually perform the diagnostic procedure are trained and are responsible for ensuring the maintenance of the necessary equipment and supplies to perform the tests.