Pulmonology Coding Alert

CPT® confirms RVUs for subsequent observation care codes 99224-99226.

Say hello to fresh time guides on initial observation care codes 99218-99220 and a new modifier for preventive service. Find all these changes and more in the pages of the new edition of the Current Procedural Terminology (CPT^®) manual, with codes that take effect on Jan. 1, 2012.

Mark Those Extra Time Guidelines To Describe 99218-99220

Brace yourself for added time guidelines for the initial observation care codes 99218-99220 this Jan. 1, 2012. These add-ons will include the following text:

This will mirror the fact that these codes will feature typical times associated with them, just as subsequent observation care codes 99224-99226 already have since they were introduced. The CPT^® committee's reason for including these codes may not be entirely apparent until the AMA's November CPT^® Symposium, but the additional typical times could help you out when coding based on time.

There are only two musts for using time as a basis for selecting an E/M code, says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a consulting firm in Tinton Falls, NJ. "If counseling/coordination of care takes up more than 50 percent of the visit, and if the code has a typical time associated with it. So by these codes now having a time reference, it sounds like we may have a way to reference time used if counseling or coordination of care takes up greater than 50 percent of a visit. In addition, this could open the door to collecting for prolonged service times if the time the doctor spends exceeds 30 minutes more than the allotted time, and the visit notes are documented as such," Cobuzzi adds.

99224-99226 Acquire Finality On RVUs

CPT^® introduced codes for subsequent observation care, 99224 (Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components: Problem focused interval history; Problem focused examination; Medical decision making that is straightforward or of low complexity), 99225 (... An expanded problem focused interval history; An expanded problem focused examination; Medical decision making of moderate complexity), and 99226 (... A detailed interval history; A detailed examination; Medical decision making of high complexity). beginning Jan. 1, 2011. During the public comment period, the American College of Physicians (ACP) questioned the relative values the Centers for Medicare and Medicaid Services (CMS) assigned for these codes. In July, however, the CMS released a clarification rendering the present relative values for 99224-99226 as final, according to the ACP Internist article "ACP disputes federal valuation of primary care observation codes" (see www.acpinternist.org/archives/2011/09/coding.htm).

CMS maintains that the following value units are final at the disputed levels, and will determine the payment levels for subsequent observation care under the Medicare fee schedule for 2011 and following years:

Note: The actual payment amount will change in 2012 if the conversion factor changes.

CMS further clarified in an August transmittal that subsequent observation care codes, as initial observation care codes, are reserved for the observation attending/group of record. Consultants shouldn't use them. If a pulmonologist were consulted during an observation case, he would report the appropriate outpatient/office code (99201-99215) with OH (Outpatient hospital) site of service. The pulmonologist would report the most appropriate new patient (99201-99205) or established (99212-99215) code, depending on whether or not the patient has been seen by the group within the last three years. Be sure your physician does not mistakenly report the observation care service codes if he is the consultant.

Quick fact: Typically, the emergency department (ED) physician or hospitalist would be the observation attending while the pulmonologist is reserved as the attending in intensivist (ICU) cases.

New 2012 Modifier Doesn't Guarantee Extra Pay

It isn't every year that CPT^® adds new modifiers for your coding and billing needs, so when you see a new one gracing the pages of your 2012 manual, you might get excited -- but don't rejoice just yet.

Modifier 33 (Preventive service) went into effect on Jan. 1, 2011, but it didn't make it into the 2011 CPT^® book due to publishing deadlines, so the modifier will be making its first appearance in the 2012 manual. According to CPT^®, the modifier should be appended "when the primary purpose of the service is the delivery of an evidence based service in accordance with a US Preventive Services Task Force A or B rating in effect and other preventive services identified in preventive services mandates."