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Otolaryngology Coding Alert

Reader Question:

Any Doctor Can Use ED Codes

Published on Thu Nov 29, 2012

Question: An emergency department (ED) physician asked our ENT to see a patient who has severe epistaxis (784.7). The ED doctor specifically requested that our doctor take responsibility for treatment of the patient, so I don't think this can count as a consult. I'm not sure, however, if I can report an ED visit for our ENT, who is not an ED physician. How should I report the visit?

New York Subscriber

Answer: A common misconception is that only ED physicians can report ED services (99281-99285, Emergency department visit for the E/M of a patient). In fact, any physician can report the ED codes if he provides a service in the ED. This does not mean, however, that an ED code is the only choice when a physician sees a patient in the ED.

According to the Medicare Carriers Manual section 15507, primary-care physicians and specialists should report an ED visit for services rendered in the ED, unless:

  • the service provided meets the criteria for a consult.
  • the physician delivers critical care services (99291-99292) upon arriving at the ED, or
  • the physician admits the patient to the hospital (99221-99223, Initial hospital care, for the E/M of a patient ...; 99218-99220, Initial observation care, per day, for the E/M of a patient ...; 99234-99236, Observation or inpatient hospital care, for the E/M of a patient including admission and discharge on the same date ...).

If the otolaryngologist provides any of these three services, you should report the respective E/M service code instead of the ED visit.

In your case, the ENT clearly accepted full care for the patient, so a consult is not an option. You don't mention any critical care services, so you wouldn't report 99291-99292, either.

If the otolaryngologist subsequently admits the patient to the hospital (99221-99223) or orders observation (99218-99220), you should report that service instead of the ED visit codes. For a same-day observation order and discharge, use 99234-99236.

As you describe your case, and because the ED physician transfers care to the otolaryngologist, you should report an ED visit, such as 9928X depending on the level of documentation. If your physician also controlled the epistaxis via a procedure, such as 30905 (Control nasal hemorrhage, posterior, with posterior nasal packs and/or cautery, any method; initial), you would code the encounter as 9928X-25, 30905.

Private payers may not play ball: Some non-Medicare guidelines may indeed insist that only ED physicians can use ED service codes 99281-99285, which can force you to report outpatient E/M or consult services in defiance of CPT and CMS rules to keep within the individual payer's guidelines and receive payment for services rendered. If your payer stipulates such rules, be sure to get its recommendations in writing and follow them to the letter.

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