General Surgery Coding Alert

CMS vs CPT®:

Confront Agency Differences for Reporting Prolonged Services

Master 3 new HCPCS Level II codes.

CPT® 2023 changes how you should code prolonged services with several code deletions, revisions, and additions. Reflecting the larger changes to evaluation and management (E/M) coding (see “Embrace E/M Shift to Time or MDM” in this issue), the prolonged services update allows you to seamlessly report lengthy visits with your general surgeons.

Caveat: But the Centers for Medicare & Medicaid Services (CMS) continues to disagree with how to account for prolonged services, which is why you need to accommodate revised and new HCPCS Level II codes for Medicare beneficiaries.

Learn These CPT® 2023 Updates

Adapting to wider E/M coding changes, CPT® 2023 takes the following actions that affect how you should code as of Jan. 1:

  • Deletes codes +99354-+99357 (Prolonged service …)
  • Revises code +99417 (Prolonged office or other outpatient evaluation and management service(s) beyond the minimum required time of the primary procedure which has been selected using total time, requiring total time with or without direct patient contact beyond the usual service, on the date required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time (List separately in addition to codes 99205, 99215 for office or other the code of the outpatient Evaluation and Management services)) (added text underlined, deleted text struck through) A revised CPT® 2023 note instructs you to “Use 99417 in conjunction with 99205, 99215, 99245, 99345, 99350, 99483.”
  • Adds code +99418 (Prolonged inpatient or observation evaluation and management service(s) time with or without direct patient contact beyond the required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time (List separately in addition to the code of the inpatient and observation Evaluation and Management service)) A new CPT® 2023 note instructs you to “Use 99418 in conjunction with 99223, 99233, 99236, 99255, 99306, 99310.”

Guidelines: “CPT® instructs you to add one unit of the code when time documented hits 15 minutes beyond the minimum E/M time ranges for the date of service with and without direct patient contact,” says Terri Brame Joy, MBA, CPC, COC, CGSC, CPC-I, product manager, MRO, in Philadelphia. Don’t count time spent on separately reportable services.

See How Medicare Judges Prolonged Service

CMS argues that you should report prolonged service when the total time for visits hit 15 minutes beyond the maximum time range.

Consequently, Medicare introduced a separate prolonged services code in 2021 to use instead of +99417 — G2212 (Prolonged office or other outpatient evaluation and management service(s) beyond the maximum required time of the primary procedure which has been selected using total time on the date of the primary service; each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact (list separately in addition to cpt codes 99205, 99215 for office or other outpatient evaluation and management services)…).

That means “G2212 is the appropriate code to represent prolonged service time for a Medicare patient when the maximum [99205 or 99215] time has been exceeded by 15 minutes,” says Leah Fuller, CPC, COC, with Pinnacle Enterprise Risk Consulting Services in Charlotte, NC.

CMS 2023: Based on disagreement about when to start counting prolonged service, the Medicare Physician Fee Schedule (MPFS) CY2023 final rule introduces three new codes to use for reporting prolonged services instead of using CPT® codes +99417 and +99418:

  • G0316 (Prolonged hospital inpatient or observation care evaluation and management service(s) beyond the total time for the primary service (when the primary service has been selected using time on the date of the primary service); each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact (list separately in addition to CPT codes 99223, 99233, and 99236 for hospital inpatient or observation care evaluation and management services)
  • G0317 (Prolonged nursing facility evaluation and management service(s) beyond the total time for the primary service (when the primary service has been selected using time on the date of the primary service); each additional 15 minutes by the physician or qualified healthcare profes­sional, with or without direct patient contact (list separately in addition to CPT codes 99306, 99310 for nursing facility evaluation and management services)
  • G0318 (Prolonged home or residence evaluation and management service(s) beyond the total time for the primary service (when the primary service has been selected using time on the date of the primary service); each additional 15 minutes by the physician or qualified healthcare profes­sional, with or without direct patient contact (list separately in addition to CPT codes 99345, 99350 for home or residence evaluation and management services)

The MPFS final rule also states that CMS is revising the long descriptor for G2212 to include reference to CPT® code 99483 (Assessment of and care planning for a patient with cognitive impairment, …) as a code that can be listed separately with G2212.

Consultation: Medicare continues to not support CPT® consultation codes, and the CY2023 MPFS final rule states that none of the prolonged-service “G” codes are applicable for reporting prolonged services.

Resource: Access the CY2023 MPFS final rule at https:// public-inspection.federalregister.gov/2022-23873.pdf