Facility charge for an infusion clinic...?

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Hello!
I am coding for a outpatient infusion clinic facility, not professional fees- Should be easy, right?! Yea, sure! My questions do not revolve around the infusion coding.

I cannot find any written resources on charging a facility E&M for an infusion services. I didn't think we could charge such a fee, as there is no clinic visit, just the infusion. So I started to research and I all I can find are articles (some quite old) that say it's not appropriate or a general statement that says a facility can charge a fee for the facility.
My lead says it because of the 'risk' of the drug infusion and 'availability" of a physician. So if I go with this, there should be ample documentation provided by the nursing staff (employed by the facility) that they are checking on the patient to warrant charging a level as well as some kind of physician documentation stating that they were monitoring.

Anyone want to chime in? Can anyone point me in the direction of resources?
Many thanks & have a groovy day! ✌️
 

thomas7331

True Blue
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I agree, if you're going to bill a facility fee for an E&M service at the same encounter, you will have to have documentation to support the use of a modifier 25 that will need go on that E&M clinic fee if billed on the same date. So you would need documentation of a 'separately identifiable' service, such as a clinic appointment with the MD on that same date that is unrelated to the infusion, or a physician service that is above and beyond the usual E&M services that are involved in any infusion. 'Checking on the patient', whether by the nursing staff or the physician, is a component of the infusion service and not something that would support the modifier.

ALL facility services do involve a certain level of risk and physician supervision/availability that is inherent in that service - you can't code and bill a separate fee just for that - otherwise the facility would be adding an E&M code to every single service that was ever billed by the facility.
 
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