ED Coding and Reimbursement Alert

Question: Can conscious sedation be billed with an evaluation and management (E/M) code? Codes 99141 and 99142 are nonstarred procedures and, according to my information, cannot be billed along with an E/M visit.

Ohio Subscriber

Answer: The AMA does not consider conscious sedation as anesthesia, and Medicare does not pay for conscious sedation. Therefore, you would bill the surgery code with the descriptor without anesthesia, then add the conscious sedation code (99141 or 99142).

In addition, according to CPT, the surgeon performing the procedure must administer the conscious sedation. This is a controversial area, even for AMA/CPT staff. The January 1999 CPT Assistant states that surgery codes with the descriptor with anesthesia refer to general anesthesia. Because conscious sedation is not considered anesthesia, coders might have to choose a surgery code, append it with the descriptor without anesthesia, and bill the conscious sedation in addition to the surgery code with an understanding that Medicare will not pay for the conscious sedation and the procedure.

When the ED physician administers the sedation and someone else performs the procedure, the physician should code either the sedation or the E/M service to reflect the higher complexity. However, in this situation, the physicians documentation must clearly indicate that the E/M service is separate from the associated procedure and conscious sedation.

Payer policy regarding this issue varies significantly and often dictates the coding solution. Confer with your carrier before billing. For more information on this subject, refer to the November 2000 ED Coding Alert.