ED Coding and Reimbursement Alert

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answer.
Question: What type of documentation is necessary to charge for EKGs and x-ray? Louisiana Subscriber   Answer: Medicare states that in order to bill for an EKG interpretation the ER physician should provide "a separate written report similar to that of a specialist in the field." Based on this, the documentation for an EKG interpretation should include rate, rhythm, axis, intervals, and whether there were any ST/T wave changes. Comparison to prior EKGs, if available for review, should also be included. The interpretation on the chart must be signed by the attending physician but does not have to be on a separate piece of paper. Standards for commercial carriers are less specific but should substantiate the clinical service provided. You should also be aware of the "political" dimension of your question. It can be advantageous to negotiate with specialists about billing for noncontemporaneous interpretations to avoid problems with hospital administration over duplicate billing. Note that contract physicians occasionally don't get much support from the hospital or physician staff in most instances in this country. (Refer to Carriers Manual part 3, 15023 Interpretations of Diagnostic Tests, "X-Rays and EKGs Furnished to Emergency Room Patients.")

However, a memo from the Foley & Lardner law firm clearly states that CMS is only willing to pay for the provider giving a contemporaneous reading of the study. If your EKGs and x-rays are being read later in the day, or the next day after patient care has already been delivered, then CMS supports the hospital as the provider with the right to bill for the study. Many hospital administrators are unaware of this ruling and with a little education can see the logic behind it. That legal opinion states, "If the cardiologist or radiologist bills for professional services that were provided later than the date on which ER services were provided, then HCFA (now CMS) will assume that such interpretation did not contribute to the diagnosis and treatment of the ER patient. HCFA will view the second interpretation as a quality-control measure provided by the hospital and will not pay for the second interpretation."