Pulmonology Coding Alert

Documentation:

The Key That Unlocks the Door to Full Critical Care Reimbursement

Reporting critical care on the same day as other services or procedures can be near impossible, but you can learn proper coding guidelines that will enable you to break the gridlock on these claims.

The problem occurs because critical care coding guidelines are stringent when it comes to the documentation needed to support medical necessity and to show that multiple services are warranted. Since a doctor's time spent with critical care patients is often complex and in-depth, it is hard to sift through the rules pertaining to time spent with patients, coverage of specific procedures, and medical necessity. Therefore, you need to be clear on what is required in order to get proper reimbursement for your time spent with critical care patients.

Coding for Multiple E/M Visits on the Same Day

It is often necessary to provide critical care services on the same day as other E/M services. Although tricky, it is possible to bill for both services on the same day and get full reimbursement. According to Mary Falbo, MBA, CPC, president of Millennium Healthcare Consulting Inc., a national healthcare consulting firm based in Lansdale, Pa., documentation and careful coding are the keys to billing for multiple E/M visits. You need to follow a few simple guidelines to optimize your reimbursement.

For example, a patient is admitted in the morning for asthma and, later in the day, goes into respiratory arrest. You would "bill the hospital admission code with modifier -25 (Significant, separately identifiable evaluation and management service by the same physician on the same day of the procedure of other service) and add up all of the time spent on critical care, and bill the codes (99291-99292) accordingly," says Renee Brown, CPC, Southeastern Lung Care, Conyers, Ga. Make sure to distinguish between the two services by using different diagnosis codes.

According to Falbo, an important tip is to associate the most specific diagnosis code that explains the critical care condition with the critical care service. The level of specificity is important because payers do not see progress notes. The linkage of codes that support medical necessity for critical care is important so that the payers, upon review of the documentation, do not downgrade the critical care service to a subsequent hospital care visit. The diagnosis codes from the 493.xx series (Asthma) would match the hospital inpatient code (99221-99233), and the respiratory arrest code (799.1) would match the critical care code (99291-99292).

There may be circumstances in which the physician sees a patient in an outpatient setting for a regular office visit and later sees the patient for critical care. For example, a 65-year-old woman undergoes an exam for emphysema. The exam is completed, and she is sent home. Later that same day, the woman returns with shortness of breath. While at the office, the patient goes into respiratory arrest and enters a critical care state.

The Medicare Carriers Manual states that when an outpatient service is performed that does not require critical care, and later the patient requires critical care, both the critical care and the E/M services may be paid. Be sure to include different diagnosis codes for each service. The diagnosis for the office visit should be emphysema (492.0-492.8), and the diagnosis for the critical care service needs to be respiratory arrest (799.1). Brown says that modifier -25 should be appended to the office visit in this circumstance also.

If the patient had undergone respiratory arrest during the earlier visit and required critical care services, then the only service reported should be critical care.

Postoperative Care Does Not Include All Critical Care Services

Deciding whether to bill for critical care on the same day as a surgical procedure can be somewhat tricky. The Medicare guidelines depend on the type of surgery performed one with a 0-, 10- or 90-day global surgery period. However, most surgeries that pulmonologists perform are minor surgeries or endoscopies with a postoperative period of 0 or 10 days. For example, Upstate Medicare Division of New York (UMD) says in its policy guide that "visits by the same physician on the same day as a minor surgery or endoscopy are included in the payment for the procedure, unless a separately identifiable service is also performed." If the postoperative period is 10 days, visits or procedures related to the surgery are not separately payable. If the period is 0 days, payment for postoperative visits is appropriate.

UMD states that postoperative critical care services provided during a global period for a seriously injured patient that are not related to the surgery are payable under the following circumstances:

  • The patient must require the constant attendance of the physician, and the critical care must be unrelated to the specific anatomic injury or surgical procedure.

  • Codes 99291-99292 must be billed with modifier -24 (Unrelated E/M service by the same physician during a postoperative period).

  • You must document that the critical care was unrelated to the surgery.

    Many of the common endoscopies and other procedures that pulmonologists perform tracheostomies (31600-31605), tracheobronchoscopy (31615) and bronchoscopies (31622-31656) have zero follow-up days. Therefore, you are allowed to bill for other E/M visits, including critical care, on the same day as the surgery when there is a separately identifiable reason for the E/M. Simply append modifier -25 to the E/M services. Separate diagnoses may not be required by your insurer. However, separate diagnoses are encouraged, if possible, to provide proof that the two services are separate and medically necessary.

    For example, a patient is admitted for pulmonary infiltrate (518.3), and a bronchoscopy is performed. Later that same day, the pulmonologist visits the patient for dyspnea (786.09), hypoxemia (799.0) and severe coughing (786.2) after he vomited and aspirated. While the patient is critical, the physician is at his bedside for 60 minutes. You need to code for the bronchoscopy using 31622 (Bronchoscopy [rigid or flexible]; diagnostic, with or without cell washing [separate procedure]). Bill for the initial hospital visit (99221-99223) with modifier -25. For any critical care service performed later on the same day, you will report 99291-25.

    How to Show Medical Necessity

    One problem that many pulmonologists face is proving medical necessity to payers in order to get reimbursed for critical care instead of the highest level of E/M subsequent hospital care (99233). Since critical care is provided if there is a high probability of imminent or life-threatening deterioration, it is important to document the level of deterioration or threat. You need to document the situation, along with the time.

    For example, a 55-year-old male is treated for severe chronic obstructive pulmonary disease. It takes extensive documentation to move this care from the level of 99233 to 99291 (Critical care ...). According to Falbo, the doctor should elaborate on why the patient's condition is life-threatening. If his pressure is 90 over 50, then describe the need for constant monitoring of blood pressure. Document "respiratory failure consistently requiring a ventilator." Clearly outline why the patient is critically ill, including specific services: changing ventilator settings, reviewing labs, changing medications. Why is the patient not able to be removed from the ventilator? Elaborate on the details of complex decision-making because the clinical facts are not sufficient when there is no change in the patient's condition during the day.

    Upon review, the insurance carrier must be able to see that the services provided truly warranted critical care. Examples of how to be more specific are as follows: Pulse thready at 130 pupils slightly reactive pressure labile metabolic acidosis requiring HCO3. The language is important. Documenting that his pupils are slightly reactive implies shock. If the physician performs a procedure that is not bundled into the critical care service, a separate note is written for the procedure. The time spent on these services is not included in the critical care time. You would place modifier -25 on the critical care code and bill for any separate procedure.

    Remember the importance of a proper diagnosis code. Cardiogenic shock would be appropriate for 99291 because the diagnosis of hypotension may not reflect the true acuity of the patient's condition. The more specific and complex the diagnosis code, the more likely you are to receive reimbursement for your critical care services.