Since outpatient and ED facilities are responsible for creating their own guidelines when it comes to E/M Coding; I would first check with your HIM Supervisor for direction on this. The facility E/M would be appropriate but the ER physician should only charge if they see the patient. I would check with the Patient's provider to see if they billed for the encounter especially if it occurred on the same day. Appropriate 25 modifier appended.
I found this on HC Pro:
Question 1: We sometimes use our ED in a clinic-type manner, but we do not have an outpatient clinic in our facility. What CPT code should we bill when a patient arrives at our ED with an order, or the patient's physician calls in an order, to change or insert a Foley catheter? We generally perform normal workup on the patient and the nurse takes the patient's information, checks his or her vital signs, and performs a brief assessment before inserting the catheter.
Answer:
Do not charge an emergency room visit for this type of service. Register these patients as outpatients as opposed to emergency room patients since they are being directed to your ED for routine and not emergency services. Develop a separate set of visit charges and criteria that will allow you to classify and bill for these visits. According to the UB-92 editor, assign a 510 revenue code to these clinic visits. This will reflect a clinic-type visit in an outpatient department, which more accurately describes the service the provider performs. Use CPT codes in the 99201-99205 range for a new patient and in the 99211-99215 range for an established patient. Ensure that you also have a full complement of possible procedures that physicians could perform in this setting. For example, if a patient is scheduled for an immunization or other type of injection, report the injection codes 90782-90788 or 90471-90472 instead of the clinic-visit code.
Best regards,
Lovina Farden,CPC