Wiki Specialist Visit to Inpt Rehab Facility

Summerville, SC
Best answers
I work for a wound clinic that has now started treating patients at an inpatient rehab facility. There is a divide among the staff about how these E/Ms would be billed.

Half the staff say - our normal office visit ems (99202-99215) with pos 11 or 61
<im quite confident billing with pos 61 would deny for pos inconsistent w e/m>

Other half say - irf em codes 99221-99233 with pos 61
<this reasoning being the idea that em codes are based on where the services take place and not the rendering provider's "home base">

we have all scoured the internet trying to find something pertaining to this and the only guidelines we can find are about how an irf should itself bill payers.


i think either way, we need a contract with the facility to reimburse us for denied services.
While I don't have specific experience with this, I can provide some guidance. It is definitively NOT POS 11. Your clinician is going to the facility, and the patient is currently admitted to a facility that the insurance is giving a daily rate to.
If you are providing E&M services only, I believe this would be billed to insurance (not to the facility), and a contract with the facility to reimburse is not required. If there are services provided with technical components (like an ultrasound), the -26 is billed to insurance and -TC is billed to the facility.
I see this billing as basically as no different than your clinicians going to a hospital to provide E&M services for admitted patients with POS 21; using 99221-99233 with POS 61.
A few years back there was a rather lively active discussion that while asking for advice about if this patient came to your office, provides several good resources quoting the CMS claims manual. Those resources are still relevant to your situation and could be helpful.