ED Coding and Reimbursement Alert

Correct Payment for ECG Interpretations Requires Accurate Documentation, Code Assignment

When a patient with a potential cardiac problem is examined in the emergency department (ED), the emergency physician often orders an electrocardiogram (ECG) and interprets the results to determine whether there is indeed a heart problem, and the nature of that problem. When the physician performs the actual interpretation of the test that he or she ordered, the physician can bill for this in addition to the evaluation and management (E/M) service delivered to the patient that day.

However, third-party payers require physicians to provide specific evidencein the form of a written reportthat the service they provided to the patient was the actual interpretation of the ECG and not just a review of data.

There must be a formal report in the patient record, and it must be detailed, advises Jan Loomis, director of coding and documentation for TeamHealth West, Inc., an emergency physician staffing company in Pleasanton, CA. It is the same detail in the report that a cardiologist would do on a final read. It is not a quick read, but a detailed interpretation.

Documentation Is Crucial to Payment

Some ED groups have had payments for these services deemed invalid in an audit due to lack of appropriate documentation, says Loomis.

According to the Health Care Financing Administrations (HCFA) Medicare rules, the documentation must include a separate report of the physicians interpretation.

Tip: The HCFA requirements for billing ECGs performed in the emergency room can be found in the Dec. 8, 1995, Federal Register. The requirements were published as part of the bulletin: Medicare Program, Revisions to Payment Policies and Adjustments to the Relative Value Units under the Physician Fee Schedule for Calendar Year 1996. The portion concerning ECGs begins on page 63130 of the document. (See insert.)

This requirement does not mean necessarily that the report must be on a separate piece of paper, but it must be separate from the rest of the documentation of the patients visit, says Pat Moore, vice president of reimbursement services for Healthcare Business Resources, Inc., an emergency medicine billing company in Durham, NC.

The HCFA rule does not say it must be on a separate page, it just has to be a separate report, she explains. So you could have the ECG interpretation written on the emergency record. But you must say ECG interpretation and then give the separate report. That is how I interpret the HCFA requirements.

Moore also notes that in a meeting with physician representatives, then-HCFA Administrator Bart McCann was asked about the rule and stated that the report did not have to be on a separate page.

What Should a Formal
ECG Interpretation Include?

Loomis says that the report should include information about the actual results of the [...]
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