EM Coding Alert

Expert: Stop reporting 99363, 99364, G0250 with these inpatient E/Ms.

The latest Correct Coding Initiative (CCI) edits shut the door on reporting hospital services along with anticoagulant management or International Normalized Ratio (INR) testing (INR) on the same patient during the same visit.

Take a quick look at how CCI 22.1, which took effect April 1, will affect your E/M coding.

Anticoagulation Wrapped into Observation Codes

On April 1, CCI enacted the following bundle: when the physician performs just about any hospital E/M for a patient, you cannot report any of the following codes in addition to the E/M:

• 99363, Anticoagulant management for an outpatient taking warfarin, physician review and interpretation of International Normalized Ratio (INR) testing, patient instructions, dosage adjustment (as needed), and ordering of additional tests; initial 90 days of therapy (must include a minimum of 8 INR measurements)
• 99364, … each subsequent 90 days of therapy (must include a minimum of 3 INR measurements) 
• G0250, Physician review, interpretation, and patient management of home INR testing for patient with either mechanical heart valve(s), chronic atrial fibrillation, or venous thromboembolism who meets Medicare coverage criteria; testing not occurring more frequently than once a week; billing units of service include 4 tests.

These edits have a modifier of 0, meaning you can never report them for the same patient during the same encounter. And since you can only code one E/M visit per day, with very few exceptions, you cannot code INR or anticoagulation therapy on the same day as a hospital visit.

The 99363, 99364, and G0250 codes are not to be reported with any of the following code sets:

• 99217, Observation care discharge day management…;
• 99218-99220, Initial observation care, per day, for the evaluation and management of a patient which requires these 3 key components …;
• 99221-99223, Initial hospital care, per day, for the evaluation and management of a patient, which requires these 3 key components …;
• 99224-99226, Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components …; and
• 99231-99233, Subsequent hospital care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components … .

Also: The bundles mean that any anticoagulation services are part of critical care services coded with 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes) and 99292 (… each additional 30 minutes [List separately in addition to code for primary service]).

Impact: When in the hospital, the providers review and convey any lab results during the time spent with the patients at the bedside or on the patient floor. Therefore, you cannot report anticoagulation testing codes separately from a hospital E/M, explains Suzan (Berman) Hauptman, MPM, CPC, CEMC, CEDC, medical coding director at Acusis, LLC, in Pittsburgh, Pa.

CCI Also Clamps Down on NF E/Ms

CCI 22.1 also put an end to reporting 99363, 99364, and G0250 with nursing facility (NF) E/Ms.

April 1 was the day CCI officially forbade coders to report 99363, 99364, or G0250 separately from:

• 99304-99306, Initial nursing facility care, per day, for the evaluation and management of a patient, which requires these 3 key components ...;
• 99307-99310, Subsequent nursing facility care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components …;
• 99315-99316, Nursing facility discharge day management …; and
• 99318, Evaluation and management of a patient involving an annual nursing facility assessment, which requires these 3 key components… .

These edits also have a modifier of 0, meaning you can never report them for the same patient during the same encounter.

Impact: INR and anticoagulation management “is included during the time and work involved in those patient visits. The results are part of the chart and easily reviewable,” Hauptman says.

“This might be the logic in why this type of service is billable in the office setting, but not in the hospital setting — but that is only speculation,” she continues.