Pulmonology Coding Alert

READER QUESTIONS:

Is ROS, HPI Critical to Critical Care?

Question: Are there rules stating my physician must have a certain amount of history of present illness (HPI) and review of systems (ROS) to bill critical care time? Our internist documented a physical examination and that he spent 30 minutes with the patient. Can I report 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes)?

Florida Subscriber

Answer: No, you do not need all the elements of the patient's HPI and ROS to report critical care codes when the physician has documented critical care time. Critical care isn't based on any of the data elements associated with E/M levels -- it's based on time for the critically ill or critically injured patient and the highly complex nature of the service. Critical care is defined as the direct delivery by a physician(s) of medical care for a critically ill or critically injured patient. A critical illness or injury acutely impairs one or more vital organ systems such that there is a high probability of imminent or life-threatening deterioration in the patient's condition.

Since critical care is a time-based code, you needn't meet all the usual elements with regard to HPI, physical examination (PE), past, family, and social history (PFSH), and ROS usually required or the E/M codes. However, your physician's documentation must reflect the nature of the patient's critical illness, the interventions provided, and that 30 minutes or more of critical care was spent outside of separately billable procedures.

The duration of critical care services to be reported is the time your physician spends evaluating, providing care, and managing the critically ill patient's care. That time must be spent at the immediate bedside or elsewhere on the floor or unit so long as the physician is immediately available to the patient and the time is solely directed toward that single patient.

Example: The time spent reviewing lab test results or discussing the patient's care with other medical staff in the unit or at the patient's nursing station on the floor may be reported as critical care, even when it does not occur at the bedside. This is correct so long as this time represents your physician's full attention to the management of the critically ill/injured patient.