Urology Coding Alert

Question: Should we consider time as a factor when billing for educational/counseling services that are provided by someone other than our urologist (such as a registered nurse or physician assistant)?

California Subscriber

Answer: In the office setting, only your urologist can consider and bill time as a factor in selecting an E/M code (such as 99211-99215, Office or other outpatient visit for the evaluation and management of an established patient ...). You should not consider a nurse or medical technician's time in choosing the appropriate code to report for counseling in the office.
 
However, the rules are not as clear for nonphysician practitioners, such as physician assistants, nurse practitioners or clinical nurse specialists. Some authorities say not to charge for the NPP's time if the urologist has already spent time counseling the patient. However, CMS' "shared visits" rule (Medicare transmittal 1776, Oct. 25, 2002) implies that the services of both the urologist and the NPP are a cumulative effort.
 
If more than 50 percent of the total service involves counseling/coordination of care, you can use the time spent by both to determine the level of visit code. Bill in the name and numbers of the physician for the total time spent. Remember that shared visits are not applicable for consultations, critical care or new patients. If the NPP alone spends time counseling and coordinating patient care, report the level of service only under the name and numbers of the NPP.
 
Don't miss: You must have documentation of the counseling time as well as the total visit time in the medical record (such as, 15 of 25 minutes spent counseling   re: ...). You should select the visit level based on the total visit time (such as, 99214 = 25 minutes). Also be sure to adhere to Medicare's "incident-to" guidelines.

 - Answers to Reader Questions and You Be the Coder contributed by Michael A. Ferragamo, MD, FACS, clinical assistant professor of urology, State University of New York, Stony Brook; and Morgan Hause, CCS, CCS-P, privacy and compliance officer for Urology of Indiana LLC, a 31-urologist practice in Indianapolis.