Primary Care Coding Alert

These 2 Components Don't Always Make 99215 Appropriate

Use medically necessary history, exam in E/M code selection

If you select 99215 when your physician performs a comprehensive history and examination, medical necessity must justify these component levels - otherwise, you could be gaming the system.

Medical Necessity Should Drive History

When determining a visit's history, the type of history - problem-focused, expanded problem-focused, detailed, comprehensive - that the family physician (FP) claims must be medically necessary based on the encounter. "The extent of the history is dependent upon clinical judgment and on the nature of the presenting problem(s)," states CPT's E/M guidelines section, "Instructions for Selecting a Level of E/M Service" (page 3 - Ingenix 2005 Expert).

Even though a nurse may take the information necessary to support a comprehensive history, the physician's clinical judgment and the patient's problem should determine the amount necessary. "Coding too many 99214s and 99215s could trigger an audit, especially if these codes are associated with one minor diagnosis," says William H. Ward, MD, IAFP, associate director of St. Francis Family Practice Residency Program in Beech Grove, Ind.

Example: An FP sees an otherwise healthy established patient for an earache. In this scenario, no medical need exists to collect a comprehensive history for a routine earache, says Daniel S. Fick, MD, director of risk management and compliance at the University of Iowa in Iowa City. 

In fact, coding a comprehensive history for such a simple problem could prove unethical, even if your staff has gathered more history than necessary. "Payers and auditors may view such conduct as 'gaming the system' - obtaining a higher-level component than medically necessary just to charge a higher-level E/M service," says Barbara J. Cobuzzi, MBA, CPC, CPC-H, CHBME, president of CRN Healthcare Solutions in Shrewsbury, N.J.

Best practice: "FPs should obtain and document the medically necessary history and use that in their coding," Fick says. The physician should "not just code for everything he or she can collect."

Exam's Extent Hinges on Problem

You also have to consider medical necessity when determining the E/M service's exam type. CPT's instructions on selecting the exam type echo its history component guidelines. "The extent of the examination performed is dependent on clinical judgment and on   the nature of the presenting problem(s)," states CPT's E/M guidelines.

Translation: A physician's decision to perform a comprehensive exam should stem from the patient's problem(s). Simple problems don't warrant this component level or the physician's time.

Example: An FP evaluates an established patient with a common cold (460, Acute nasopharyngitis [common cold]) and no comorbidities. "Even if the FP performs and documents a comprehensive exam, no one would claim it was medically necessary," says Kent J. Moore, manager of Health Care Financing and Delivery Systems for the American Academy of Family Physicians in Leawood, Kan.

Other examples that may not warrant a comprehensive exam include an established patient visit for:
 

  • Recheck for otitis media (such as 382.00, Acute suppurative otitis media without spontaneous rupture of ear drum) or cystitis (for instance, 595.9, Cystitis, unspecified) that is now resolved in an otherwise healthy patient.
     
  • Evaluation of a wart (078.10, Viral warts, unspecified) or benign-appearing mole, such as dermal nevus or seborrheic keratosis (702.19, Other seborrheic keratosis), tinea corpora (110.5, Dermatophytosis; of the body), tinea pedis (110.4, ... of foot), etc.
     
  • Subconjunctival hemorrhage (372.72, Conjunctival hemorrhage).

    Taking a comprehensive exam when the patient's problem doesn't warrant this level isn't customer-friendly. "It subjects the patient to a more extensive exam than necessary," Cobuzzi says. You should instead allow the patient's problem to drive the examination.

    Don't Confuse MDM With Medical Necessity

    To bullet-proof your 99215s, stress medical necessity's role in E/M-level selection. "Medical necessity always has to come into play," Cobuzzi says. "You shouldn't code 99215 just because the physician performs and documents two of the three components." The history and exam have to be medically necessary.

    Problem: Some coders confuse medical necessity and medical decision-making (MDM). "They're not the same thing," Cobuzzi says.

    This myth leads coders to think that MDM must always steer the E/M level. "But you may ethically have a level-five established patient office visit without high- complexity MDM," Cobuzzi says.

    Example: You could code 99215 for an established patient who has diabetes (250.xx, Diabetes mellitus) and chronic sinusitis (473.9, Unspecified sinusitis [chronic]). Even though the case may involve only moderate risk and straightforward medical decision-making, medical necessity could justify a high-level service, Cobuzzi says.

    Why: The patient has an extensive history with an ongoing problem involving complications.

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