Primary Care Coding Alert

Heed New Transmittal When Compiling Critical Care Time or Face Denials

Medicare release clears up family counseling, concurrent care rules If you can spot critical care indicators, and your FPs are diligent about documenting encounter specifics, you can capture critical care each time the physician provides it. To help coders with this process, CMS released transmittal 1530 on June 6 (http://www.cms.hhs.gov/Transmittals/downloads/R1530CP.pdf). This document puts all critical care coding guidance in one easy-to-access place, says Carol Pohlig, BSN, RN, CPC, ACS, senior coding and education specialist at the University of Pennsylvania department of medicine in Philadelphia. The transmittal, effective July 1, makes especially clear points on documenting family counseling time and coding for concurrent critical care. Keep it handy when you-re coding for 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]). Use CMS List of Approved -Counseling- Activities The transmittal spells out exactly what interactions with the patient's family you can count toward overall critical care time, confirms Pohlig. According to the transmittal, "CPT codes 99291 and 99292 include pre- and post-service work. Routine daily updates or reports to family members and/or surrogates are considered part of this (included) service." So if the FP meets for three minutes with a patient's wife to give her an update, you should not count this as critical care time. Exception: When the critically ill or injured patient is unable or incompetent to give a medical history or make treatment decisions and a discussion to determine treatment decisions is necessary, you can count time spent consulting with the family toward critical care. You-ll need to be sure to document the family counseling time properly, Pohlig warns. When recording family counseling time for critical care, the transmittal states that the provider must document: - that "the patient is unable or incompetent to participate in giving history and/or making treatment decisions; - the necessity to have the discussion (e.g., -no other source was available to obtain a history- or -because the patient was deteriorating so rapidly I needed to immediately discuss treatment options with the family-); - medically necessary treatment decisions for which the discussion was needed; and - a summary in the medical record that supports the medical necessity of the discussion." Show Physicians the Value of Documentation Your FPs also need to be diligent about documenting the other critical care components. Often, physicians do not provide enough information on encounter forms to justify critical care coding. "Critical care is commonly performed but underreported. I believe many (physicians) often miss critical care coding opportunities," said Caral Edelberg, CPC, CCS-P, CHC, president of Medical Management Resources for TeamHealth in Jacksonville, Fla. [...]
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