Primary Care Coding Alert

Question: In the Amount and/or Complexity of Data to be Reviewed and Analyzed element of medical decision making (MDM), moderate level Category 2 states, “Independent interpretation of a test performed by another physician/other qualified health care professional (not separately reported).” Does this mean that when my provider reviews a magnetic resonance imaging (MRI) scan, I can count this as a point?

AAPC Forum Participant

Answer: To answer this question, you should refer to the CPT^® office or other outpatient services evaluation and management (E/M) guidelines, which define “independent interpretation” as “the interpretation of a test for which there is a CPT^® code and an interpretation or report is customary. This does not apply when the physician or other qualified health care professional is reporting the service or has previously reported the service for the patient. A form of interpretation should be documented but need not conform to the usual standards of a complete report for the test.”

In short, if your provider reviews an MRI that an outside provider performed, you can count the review under Category 1, but not as an independent interpretation under Category 2. However, if the provider reviews and interprets MRI images that an outside provider performed, then you can count it as an independent interpretation. However, it’s important to remember that if your provider reviews or interprets an MRI report that they billed separately, that review/interpretation cannot be counted toward medical decision making (MDM) because it is already included in the separate billing for the MRI interpretation and report. This would be considered fraudulent even if it occurred at a subsequent visit because the provider would be seen as attempting to be paid twice for the same service. As noted in the definition of “independent interpretation” above, independent interpretation for purposes of MDM “does not apply when the physician or other qualified health care professional is reporting the service or has previously reported the service for the patient.”