Practice Management Alert

Here’s the trio of codes you should stop reporting with inpatient E/Ms.

The latest Correct Coding Initiative (CCI) edits shut the door on reporting hospital services along with anticoagulant management or internalized normalized ration (INR) on the same patient during the same visit.

Take a quick look at how CCI 22.1, which took effect April 1, will affect your hospital evaluation and management (E/M) coding.

Anticoagulation Wrapped into Observation Codes

On April 1, CCI enacted the following bundle: When the physician performs just about any hospital E/M for a patient, you cannot report any of the following codes in addition to the E/M:

• 99363, Anticoagulant management for an outpatient taking warfarin, physician review and interpretation of International Normalized Ratio (INR) testing, patient instructions, dosage adjustment (as needed), and ordering of additional tests; initial 90 days of therapy (must include a minimum of 8 INR measurements)
• 99364, … each subsequent 90 days of therapy (must include a minimum of 3 INR measurements) 
• G0250, Physician review, interpretation, and patient management of home INR testing for patient with either mechanical heart valve(s), chronic atrial fibrillation, or venous thromboembolism who meets Medicare coverage criteria; testing not occurring more frequently than once a week; billing units of service include 4 tests.

These edits have a modifier of 0, meaning you can never report them for the same patient during the same encounter. And since you can only code one E/M visit per day, with very few exceptions, you cannot code INR or anticoagulation therapy on the same day as a hospital visit, relays Suzan (Berman) Hauptman, MPM, CPC, CEMC, CEDC, medical coding director at Acusis, LLC, in Pittsburgh, Pa.

Beginning this past April 1, you should not report 99363, 99364, or G0250 with any of the following code sets:

• 99217, Observation care discharge day management…;
• 99218-99220, Initial observation care, per day, for the evaluation and management of a patient which requires these 3 key components …
• 99221-99223, Initial hospital care, per day, for the evaluation and management of a patient, which requires these 3 key components …
• 99224-99226, Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components …
• 99231-99233, Subsequent hospital care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components ….

CCI 22.1 also bundles 99363, 99364, and G0250 into critical care services that you would code with 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes) and 99292 (… each additional 30 minutes [List separately in addition to code for primary service]).

The reason for all of these edits is pretty basic, Hauptman explains. When a patient is in the hospital, the providers review and convey any lab results during the time spent with the patient at the bedside or on the patient floor. Therefore, reviewing and conveying lab results in these situations is not a separately reportable service; it’s part of the hospital E/M, explains Hauptman.

CCI Makes Similar Edits to NF Codes

CCI 22.1 also put an end to reporting 99363, 99364, and G0250 with nursing facility (NF) E/Ms.

April 1 was the day CCI officially forbade coders the aforementioned trio of codes separately from:

• 99304-99306, Initial nursing facility care, per day, for the evaluation and management of a patient, which requires these 3 key components ...
• 99307-99310, Subsequent nursing facility care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components …
• 99315-99316, Nursing facility discharge day management …
• 99318, Evaluation and management of a patient involving an annual nursing facility assessment, which requires these 3 key components….

These edits also have a modifier of 0, meaning you can never report them for the same patient during the same encounter.

As with the hospital codes, this CCI edit is a slam dunk. INR and anticoagulation management “is included during the time and work involved in those patient visits. The results are part of the chart and easily reviewable,” Hauptman says.

Remember: These edits apply to hospital and NF services. If the physician performs

“This might be the logic in why this type of service is billable in the office setting, but not in the hospital setting — but that is only speculation,” she continues.