ED Coding and Reimbursement Alert

Question: What is the rule of supervision of a procedure in ED? Must I, the supervising physician, be present during the whole procedure if is done by resident or student? If I wasn't in the room for the procedure, I assume that I can't say I directly supervised. Correct?

Massachusetts Subscriber

Answer: Assuming this is a Medicare patient (or a patient whose insurance follows Medicare's teaching physician rules), it's not billable at all if the procedure was performed by solely the student. If you are physically present and participate in the procedure along with the student, you should be able to report the service as if you did it yourself with the student acting as an assistant.

For a resident, the minor procedure designation for teaching physician rules is different than the rules for global surgeries. A zero or 10 day global designation is not the determining factor for teaching physicians. The determining factor is how long the procedure takes. CMS defines a minor procedure as one that takes 5 minutes or less to perform. If it takes more than 5 minutes it is a major procedure.

The Medicare manual uses simple suture as an example of a minor procedure but in reality even those usually take more than 5 minutes and many groups apply the major procedure guidelines.

For a minor procedure, the teaching physician must be present for the entire procedure in order to bill for the procedure.

For a major procedure the teaching physician must be present for the key/critical aspects of the procedure. Of note, it is at the attending physician's discretion to determine which aspects of the procedure represent the key/critical components.