Wiki “Professional Fee Billing for Trauma Services”

kwrenn

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Hello,
I’m currently an anesthesia coder preparing to transition into trauma pro fee coding for a group of general surgeons. I’m looking for helpful resources or guidance to get familiar with trauma-specific coding requirements — especially around E/M coding, Place of Service (POS) codes, and procedure billing.

I have a few specific questions I’m hoping someone can help clarify:
  1. When a patient presents through the ER, is evaluated by the trauma surgeon, and placed in observation, would the correct POS code be 22 (Outpatient Hospital)? In that situation, would the appropriate E/M code typically come from the 99221–99223 (Initial Hospital/Observation Care) series?
  2. If the trauma surgeon admits the patient as an inpatient, should the POS be 21 (Inpatient Hospital), and would E/M codes again fall under 99221–99223, and/or 99291–99292 if critical care is documented?
  3. Is it uncommon for a trauma surgeon to bill using ER E/M codes (99281–99285) with POS 23 (Emergency Room – Hospital)? Under what scenarios would POS 23 be appropriate for the trauma provider?
  4. I understand that trauma surgeons may also perform billable procedures, such as intubations or central lines. In those cases, is it appropriate to append modifier 25 to the E/M code when the evaluation and procedure are both performed during the same encounter?
Any insights, coding examples, or recommendations for training materials or references specific to trauma pro fee billing would be greatly appreciated.

Thank you in advance for your time!
 
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I have a few specific questions I’m hoping someone can help clarify:
  1. When a patient presents through the ER, is evaluated by the trauma surgeon, and placed in observation, would the correct POS code be 22 (Outpatient Hospital)? In that situation, would the appropriate E/M code typically come from the 99221–99223 (Initial Hospital/Observation Care) series? You report the POS of the level that the patient is in at the time of the face to face visit. Generally, the order is placed for admission during the face to face, so that's the POS that's used.
  2. If the trauma surgeon admits the patient as an inpatient, should the POS be 21 (Inpatient Hospital), and would E/M codes again fall under 99221–99223, and/or 99291–99292 if critical care is documented? correct.
  3. Is it uncommon for a trauma surgeon to bill using ER E/M codes (99281–99285) with POS 23 (Emergency Room – Hospital)? Under what scenarios would POS 23 be appropriate for the trauma provider? yes, the trauma surgeon can consult in the ED. this might happen if the patient is later admitted to another service (for example, if ortho admits the patient), or if the patient is transferred to another facility. Or if the admission happens the next calendar day.
  4. I understand that trauma surgeons may also perform billable procedures, such as intubations or central lines. In those cases, is it appropriate to append modifier 25 to the E/M code when the evaluation and procedure are both performed during the same encounter? unless the E&M code is for critical care and those procedures are an inherent part, you would generally bill the procedures if the trauma surgeon personally performed them, and add the -25 modifier to the associated E&M service. So if the respiratory therapist intubates the patient in the ED, that wouldn't be billed by the trauma surgeon.
 
@Pam Warren This is very helpful. I'm probably over thinking it, but I just want to make sure I'm interpreting your response to question 1 correctly ~ "Generally, the order is placed for admission during the face to face, so that's the POS that's used" ~ So when a trauma surgeon has an initial face-to-face encounter with a patient in the ED and decides to admit the patient as inpatient (POS 21) or place them in observation status (POS 22) during that same visit, the appropriate place of service would be 21 or 22, and the corresponding Initial Hospital Inpatient/Observation care codes (99221–99223) would be billed?

In contrast, if the trauma surgeon evaluates the patient in the ED but does not admit or place them in observation, then the appropriate place of service would be 23 (ER), and ED E/M codes (99281–99285) would be used? Additionally, consult codes wouldn’t typically be billed in place of ED E/M codes, since most payers no longer recognize or reimburse CPT consult codes (99241–99245 / 99251–99255). Is that correct?

Thanks again!
 
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Yes---- the POS changes as soon as the order is placed....usually during the face to face visit, wherever that takes place. so if the trauma surgeon is in the ED, he places the order at that time for an inpatient admission, then you'd report POS 21 (and code the initial hospital visit). You're right that most payers don't accept consultation codes, so the initial hospital visit is almost always used. The -AI modifier is added if the trauma surgeon is the attending on record.
 
Yes---- the POS changes as soon as the order is placed....usually during the face to face visit, wherever that takes place. so if the trauma surgeon is in the ED, he places the order at that time for an inpatient admission, then you'd report POS 21 (and code the initial hospital visit). You're right that most payers don't accept consultation codes, so the initial hospital visit is almost always used. The -AI modifier is added if the trauma surgeon is the attending on record.
Got it, thanks. Regarding the AI modifier, do all payers recognize and accept it? And is it only appropriate to append the AI modifier on the initial hospital visit codes (not the subsequent codes) when the trauma surgeon is the attending physician on record?
 
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I would add it to all initial hospital visits when the admitting doc is reporting that code. It's only for initial visit, and only for admitting providers. Most payers accept this modifier; appending it shouldn't matter if the payer doesn't recognize it.
 
@Pam Warren ~ Hi Pam! I was wondering if you have any recommendations for MDM training. I haven’t coded MDM in quite a few years and haven’t done so since the implementation of the new guidelines. While I’ve read through the updated guidelines thoroughly, I believe that some additional training or a workshop would be especially helpful. Any suggestions you might have would be greatly appreciated.

Thank you again for your time!
 
I'd recommend reaching out to NAMAS. They have excellent training and newsletters. Also, AAPC's workshops and webinars, and local chapter meetings (you can attend most of them virtually, even if you're not a member of that local chapter).
 
@Pam Warren ~ May I ask you another question pertaining Trauma billing?

If a general trauma surgeon (or same group) admits a patient and later performs surgery on them (either the same day or a few days later), does the surgeon (& group) enter the surgical global period and become unable to bill separately for discharge services—even if the trauma services and surgical services are billed under different tax IDs? Would billing separately for discharge in this case be considered double dipping? Or, to bill for the discharge, would the services need to be related to diagnoses other than the surgery?

Any insights you can provide would be greatly appreciated!

Thank you!
 
@Pam Warren ~ May I ask you another question pertaining Trauma billing?

If a general trauma surgeon (or same group) admits a patient and later performs surgery on them (either the same day or a few days later), does the surgeon (& group) enter the surgical global period and become unable to bill separately for discharge services—even if the trauma services and surgical services are billed under different tax IDs? Would billing separately for discharge in this case be considered double dipping? Or, to bill for the discharge, would the services need to be related to diagnoses other than the surgery?

Any insights you can provide would be greatly appreciated!

Thank you!
For professional services, the trauma surgeon enters the global period if they are performing the surgery and thus would not be able to bill any additional services related to that surgery, including a discharge summary. TIN is irrelevant....it is based on the performing provider and his/her covering providers. Generally, conditions outside the reason for surgery (i.e. co-occurring DM or HTN) are managed by hospitalists, who can bill E&M services for that care. A great deal of information regarding these scenarios are available for you to review under the NCCI, which should be helpful for specific surgical scenarios. https://www.cms.gov/national-correct-coding-initiative-ncci
 
@Pam Warren ~ Thank you! I’ve reviewed the NCCI guidelines, but I just wanted to confirm that the Trauma daily rounding visits performed by the attending trauma surgeon (or another provider in the same group) who performed the surgery are included in the surgical global package. I apologize if I’m being repetitive — I just want to be sure I’m interpreting the NCCI correctly. Thanks!!
 
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@Pam Warren ~ Thank you! I’ve reviewed the NCCI guidelines, but I just wanted to confirm that the Trauma daily rounding visits performed by the attending trauma surgeon (or another provider in the same group) who performed the surgery are included in the surgical global package. I apologize if I’m being repetitive — I just want to be sure I’m interpreting the NCCI correctly. Thanks!!
It depends on the documentation. I have seen where a multi trauma patient had surgery day 1 or 2 yet some rounding notes days later include the surgical post op but also include addressing other things. In most cases, if the trauma doc or their PA (example) is rounding, and the documentation only addressed the condition or issues that is now in a global, it is included. You have to read the note though, don't assume something else didn't come up. There are lots of times other problems and issues pop up later especially in a big trauma case where there were multiple injuries and once the "big" ones were addressed, the patient may notice or start to complain of other problems.
It's not the fact that they are doing "daily rounds", it is what are they addressing while doing it?
 
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