We are struggling with interpreting Medicare's direction when it comes to the time requirements to bill 99292 for Critical Care split/shared. Per the internet-only manual at https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c12.pdf, for critical care split/shared (section 30.6.12.5, we determine time as follows: "To bill split (or shared) critical care services, the billing practitioner first reports CPT code 99291 and, if 75 or more cumulative total minutes are spent providing critical care, the billing practitioner reports one or more units of CPT code 99292."
Above this section are a couple sections (30.6.12.3 and 30.6.12.4) discussing critical care furnished concurrently. For this concurrent care, the instructions are to code as follows: "Once the cumulative required critical care service time is met to report CPT code 99291, CPT code 99292 can only be reported by a practitioner in the same specialty and group when an additional 30 minutes of critical care services have been furnished to the same patient on the same date (74 minutes + 30 minutes = 104 total minutes)."
Our facility does mostly split/shared critical care. I haven't really seen any concurrent care services documented for providers of the same specialty and group. The documentation supports that either the visits are split/shared or a provider sees the patient alone.
So, would we code based on the section about critical care split/shared? Or concurrent care?
To make things a little harder, there is conflicting information out there about this. For example, at this site it states:
"Q3. Does the CY 2022 final rule provide that a physician or NPP spending more than 74 minutes providing critical care services to a patient on a given date may report CPT code 99292?
A3. No, as finalized in the CY 2022 rule a physician or NPP spending more than 74 minutes providing critical care services to a patient on a given date may report CPT code 99292 only when they have spent a whole additional 30-minute time increment (in other words, when 104 minutes have been spent), and may bill 99292 for each additional 30-minute time increment completed"
Would love to get the thoughts of others on this.
Thank you!
Above this section are a couple sections (30.6.12.3 and 30.6.12.4) discussing critical care furnished concurrently. For this concurrent care, the instructions are to code as follows: "Once the cumulative required critical care service time is met to report CPT code 99291, CPT code 99292 can only be reported by a practitioner in the same specialty and group when an additional 30 minutes of critical care services have been furnished to the same patient on the same date (74 minutes + 30 minutes = 104 total minutes)."
Our facility does mostly split/shared critical care. I haven't really seen any concurrent care services documented for providers of the same specialty and group. The documentation supports that either the visits are split/shared or a provider sees the patient alone.
So, would we code based on the section about critical care split/shared? Or concurrent care?
To make things a little harder, there is conflicting information out there about this. For example, at this site it states:
"Q3. Does the CY 2022 final rule provide that a physician or NPP spending more than 74 minutes providing critical care services to a patient on a given date may report CPT code 99292?
A3. No, as finalized in the CY 2022 rule a physician or NPP spending more than 74 minutes providing critical care services to a patient on a given date may report CPT code 99292 only when they have spent a whole additional 30-minute time increment (in other words, when 104 minutes have been spent), and may bill 99292 for each additional 30-minute time increment completed"
Would love to get the thoughts of others on this.
Thank you!