CMS transmittal clears up family counseling, concurrent care rules To capture valuable critical-care time each time the pulmonologist provides it, coders need to spot critical care indicators -- and doctors need to be diligent about documenting encounter specifics. CMS released transmittal 1530 on June 6 (
http://www.cms.hhs.gov/Transmittals/downloads/R1530CP.pdf), which helps providers with this process. 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 7, 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]). Check Out 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 pulmonologist meets for three minutes with a patient's wife to give her an update, this cannot be counted as critical care time. Exception: When the patient is unable or too cognitively impaired to give a medical history or make treatment decisions, you can count time spent consulting the family toward critical care. You can also include time spent discussing treatment decisions, if the pulmonologist has to ask a family member about any allergies to medications, for example. 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." Important: Family meetings must occur on the patient's unit/floor so the physician remains immediately available to the patient. Discussions that take place in another location are included in the pre- and/or post-service work associated with critical care. You cannot count any interactions with family members that do not meet the above criteria, warns Catherine [...]
