Question Category 1 MDM and in-house CT, billing only TC


Clay, NY
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Good Morning,
I am looking for clarification on the new 2021 EM MDM scoring for the Amount and/or Complexity of Data to be Reviewed and Analyzed Category 1. (I also posted this in auditing forum.) We are a moderate sized multi speciality oncology group. We own our lab and CT scanner.

Question: Do we get credit for ordering lab tests or CT scans done at our facility for those tests where we do not provide the professional component?

Example: We bill 74150(TC mod) for a CT-abd on the equipment we own. The professional reading is done by a group not associated with our practice. Would we be able to use this CT as an point for the Medical Decision Making (outpatient)? I already understand that if we provide both technical and professional components of a test that it does not count and is considered "double dipping". Thank you for your help


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Asked a colleague, and she said:

So if they aren’t billing for the labs and or CT tests then they can count them. If they are billing for the lab/test separately, then they cannot count this under the data section…even under Category 1. They consider this double dipping because the order/review is implied as a part of the service that lab/test being billed out. Hope that makes sense.


True Blue
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This is still an area of confusion and controversy and I hope that some clarification will be published soon. In my opinion, the technical component of a service has no overlap with the physician work involved in an E&M service, so there would be no 'double-dipping' involved in the situation you describe. The guidelines are quite clear that the work that is billed separately by the physician (e.g. interpretation) would not be counted toward MDM, but there is no reason I can see that the technical services billed by the practice or organization itself that don't involve the physician would not count toward a physician's MDM level.