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Question Preventive Visit/AWV Initiated During a Problem-Focused Encounter?

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Oklahoma City, OK
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Subject: Preventive Visit/AWV Initiated During a Problem-Focused Encounter?

I am looking for guidance, preferably with CPT Assistant, AMA, CMS, or other authoritative references, regarding preventive medicine services (99391-99397) and Medicare Annual Wellness Visits (G0438/G0439) that are performed during encounters that were initiated for a problem or complaint.

We have a disagreement between our coding department and some providers regarding whether a preventive medicine service or AWV can be reported when the patient presents for evaluation of a condition and the provider then decides to perform preventive services during the same encounter.

Example:

A patient schedules an appointment for vaginal itching. During the visit, the provider spends only a few minutes addressing the itching but then performs what they consider a complete annual exam, including preventive history, screening recommendations, Pap smear, preventive counseling, and preventive labs.

The provider's position is that the "intent" of the visit should be determined by what was actually performed and documented during the encounter. Therefore, if the majority of the visit becomes preventive in nature, they believe the preventive medicine service (or AWV) should be billable, with or without a separate E/M service.

The coding team's position is that preventive medicine services and AWVs are intended to be preventive encounters. If the patient presents with a complaint or problem requiring evaluation, the encounter is initially problem-oriented. In that situation, a separate preventive service would need to independently meet all requirements and be clearly distinguishable from the problem-oriented work. We are concerned that routinely converting problem-focused visits into preventive visits solely because preventive services were also performed could create audit risk.

A few questions for the group:

  1. For CPT 99391-99397, does the patient's reason for presenting (chief complaint/presenting problem) affect whether the preventive medicine service is supported?
  2. Are there CPT Assistant, AMA, CMS, or Medicare Contractor references that discuss whether preventive medicine services can be initiated during encounters that begin as problem-focused visits?
  3. Does the same analysis apply to Medicare Annual Wellness Visits (G0438/G0439), or can an AWV be performed and billed when the patient presents primarily for evaluation of an illness or complaint?
  4. How are your organizations handling situations where a patient is scheduled for a problem-focused visit but the provider decides to perform an annual preventive exam or AWV during the same encounter?
I am especially interested in authoritative references rather than payer-specific policies or local practice patterns.

Thank you for any insight.
 
I recently made a reference sheet for a new coworker regarding this very scenario. I hope it helps.

You can add a problem visit to a preventive exam—
but cannot turn a problem visit into preventive after
A problem visit cannot be converted to a preventive visit just because a full exam was completed.

The reason the patient presents drives the visit type
—not what ends up being done.
Ø Preventive visits = routine, asymptomatic care
Ø Problem visits = symptoms or complaints

Preventive Visits (99381–99397)
Ø Use when no active complaint is present.
Ø Focus on screening, risk assessment, and counseling.
Ø Not for evaluation or treatment of active problems.


Problem Visits (99202–99215)

Ø Use when patient presents with a complaint.
Ø Requires chief complaint and medical necessity.
Ø

BILL BOTH TYPES OF VISITS IF:
Preventive service is fully performed
Problem is significant and separately addressed
Documentation clearly separates both services
Documentation Tips
Separate Problem Visit and Preventive Exam sections
Include distinct assessment and plan
Ensure clear separation of intent

Medicare AWV
Used for prevention only
Does not include problem-oriented evaluation
May bill AWV + problem visit if criteria met

Audit Risks
Converting sick visits to preventive
No separation of services


ScenarioCoding
Patient comes for annual exam, mentions itching 9939x + 9921x (-25)
Patient comes for itching, provider also does physical Usually 9921x only
Both are clearly separate & documented 9939x + 9921x (-25)

REFERENCES
https://www.aapc.com/blog/42585-chief-complaint-required/
https://www.ama-assn.org/health-car...ysicians-bill-both-preventive-and-em-services
https://www.cms.gov/training-educat...ovider-compliance-tips/annual-wellness-visits

 
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