Cardiology Coding Alert

Reader Question:

99211 Has Limited Role in Coumadin Encounter

Question: We're trying to create a policy on when to report an E/M code when a patient presents for Coumadin monitoring. Are there any official rules on this?

Virginia Subscriber

Answer: Your Jurisdiction 11 Medicare Administrative Contractor (MAC), Palmetto GBA, offers the following guidelines on reporting 99211 (Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem[s] are minimal. Typically, 5 minutes are spent performing or supervising these services) in addition to venipuncture for drug treatment monitoring.

First, to report 99211 in addition to the venipuncture code, the licensed auxiliary personnel must perform a face-to-face service. As part of that service, the provider must document one or both of the following:

  • "A minimal presenting problem/symptom"
  • "A relevant and necessary exchange of information between licensed personnel and the patient."

If the service and documentation don't meet the above requirements, you should not report 99211 for theauxiliary personnel's service.

Helpful: For any maintenance therapy, patient education and counseling is crucial. Palmetto expects this to occur during the initial treatment plan and E/M service. But if the auxiliary provider simply repeats the information when the patient presents for monitoring, you should not bill 99211 separately. "Palmetto GBA does not consider repetitive 'boiler plate' documentation or repeated education/counseling after the initial patient visit as reasonable and necessary."

Learn more: To find the Palmetto instructions, head to www.cms.gov/medicare-coverage-database/. Under the Quick Search, enter A51050 in the Document ID box. Additionally, CMS Medicare Claims Processing Manual (Pub. 100-04), Chapter 16 Laboratory Services, §30.4 (www.cms.gov/manuals/downloads/clm104c16.pdf) explains that reviewing lab tests is payable by Medicare, but it's included in the E/M service.