Pulmonology Coding Alert

Reader Questions:

Look Death in the Face for Appropriate Discharges

Question: A nursing facility called our pulmonologist because one of our established patients had died. Our pulmonologist pronounced the patient dead and completed all necessary paper work. Should I charge for our pulmonologist's services and with what codes?


Maine Subscriber
Answer: You could code the service with the appropriate nursing facility discharge code (99315-99316, Nursing facility discharge day management ...). Choose the code that best describes the physician's services.
 
Myth buster: Don't assume that because Medicare covers only face-to-face encounters, you shouldn't charge death pronouncement services.

An individual is not considered dead until a legal authority, usually a physician, pronounces the patient dead, according to CMS. Thus, the examination that leads to the patient's pronouncement involves a face-to-face covered encounter. (Medicare's explanation appears in CMS Manual System, Pub 100-3, Medicare National Coverage Determinations Manual, Chapter 1, Section 70.4 [http://www.cms.hhs.gov/manuals/103_cov_determ/ncd103cl_Part1.pdf].)

Problem: CPT contains no death pronouncement code. Therefore, you should use the code that best describes the services the pulmonologist renders to the patient during the pronouncement of death. Check with your carrier for details.

For instance, Noridian (Medicare Part B for 11 Western states) recommends using nursing facility discharge codes (99315-99316) "if the primary service provided is the pronouncement of death, completion of the death summary and discussion with the deceased patient's family." CPT Assistant (November 2002) also advises coding pronouncement of death using 99315 or 99316.

Important reminder: Specialists, such as pulmonologists, cannot report the nursing facility codes (99301-99303, 99311-99313, or 99315-99316) unless they are, as CPT Assistant defines it, the "admitting physician who certifies the NF services and plan of caring, assuming responsibility for all medical care. If the pulmonologist has not assumed total care for this patient throughout the NF stay, the patient's primary NF care provider should be notified to pronounce death."
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