Cardiology Coding Alert

Question: Can I report moderate sedation codes like 99152 for my cardiologist if the procedure she performs is in the facility setting? The cardiologist oversees, but the facility staff is involved.

Codify Subscriber

Answer: Consultants support the idea that you may report 99151 (Moderate sedation services provided by the same physician or other qualified health care professional performing the diagnostic or therapeutic service that the sedation supports, requiring the presence of an independent trained observer to assist in the monitoring of the patient's level of consciousness and physiological status; initial 15 minutes of intraservice time, patient younger than 5 years of age) and 99152 (... initial 15 minutes of intraservice time, patient age 5 years or older) for the physician in the facility setting.

Rationale: When you compare the values the Medicare Physician Fee Schedule (MPFS) gives to 99151 and 99152 performed in the nonfacility and facility settings, the nonfacility values are much higher. For example, the national MPFS nonfacility rate for 99152 is $52.04, but the facility price comes in at the much lower rate of $12.56. The variation suggests Medicare took into account how the services will differ in those settings for the physician when setting the rates.

Another element to consider is that the MPFS RVU files have a Facility NA Indicator column. The entry of "NA" in that column would mean "the procedure is rarely or never performed in the facility setting," according to the definition-filled PDF that accompanies the RVU files at www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/PFS-Relative-Value-Files-Items/RVU17A.html. For both 99151 and 99152, the Facility NA Indicator column is blank, meaning NA is not present in the column.

In contrast, +99153 (... each additional 15 minutes intraservice time [List separately in addition to code for primary service]) does have an NA in the Facility NA Indicator column, so according to Medicare, +99153 "is rarely or never performed in the facility setting." Another way +99153 is different is that the MPFS assigns no work RVUs for +99153. Both 99151 and 99152 do have work RVUs. Also, add-on code +99153 has a PCTC indicator of 3, which means it's a technical component only code. Both 99151 and 99152 have a PCTC indicator of 9, meaning the concept of professional (physician work) and technical (such as staff and equipment) doesn't apply to those codes.