Wiki Time documentation for discharge

[plarabee]

99238 for discharge day services indicates 30 minutes or less.. 99239 indicates that it is more than 30 minutes. I am doing education on a provider where they have an outside auditor doing the actual audit. I just came across an audit sheet where the outside company audited the doctors services. Of the 37 charts that were documented, 15 of those were down coded to 99238 from 99239. The physician had documented greater than 30 minutes spent in discharge. The audit group has notes on all of those visits indicating that type of documentation was inappropriate and they needed to have actual clock time recorded in the visit. I have never heard of this and I have been auditing for more than 20 years. I have researched and cannot seem to find anything from CMS or CPT that indicates this. Did I miss something somewhere down the line? Because if the audit company is applying time documentation incorrectly I need to know and educate them before I educate the physician.

Thanks so much for any feedback!

Patricia Larabee

 

[MBCoding]

Here are 2 references: The first is from FAQ on the Novitas website. The second is from the Palmetto GBA website.

"Hospital discharge day management codes 99238 (30 minutes or less) and 99239 (more than 30 minutes) are time based so it is imperative that medical documentation reflect total time spent by a physician during the discharge of a patient."

Does time need to be documented in order to submit for a hospital or nursing facility discharge service?
Answer:
Yes, the time must be documented in the medical record to support the level of service billed for CPT codes 99238, 99239, 99315 and 99316.
Example: CPT code 99239 is used for a hospital discharge more than 30 minutes. Therefore, the discharge note would state, "45 minutes spent performing discharge services."

 

[plarabee]

Thanks for your response. Sou you would say that a statement of "greater than 30 minutes spent on discharge" is not sufficient? Appreciate the feedback.

 

[thomas7331]

I have never heard of this either - in my work with hospital professional coding, I've never seen a discharge summary downcoded for this reason, and the language 'greater than xx minutes' is very widely used.

If I were in your shoes, I would ask the audit company to cite a reference since they are the ones who've made this determination. After all, part of what these companies are hired and paid for is to give you information like this, which usually includes feedback based on their experience with other clients and payers. Perhaps they've encountered payers who have rules for such wording. In my experience, the better audit companies will audit based on this kind of background, whereas I think some other audit companies seem to simply to try to find as many mistakes as they can in order to try to make it look like they are doing more work.

 

[TTcpc]

I've worked a lot with hospitalists and other inpatient providers and have never run across this either. While we do educate that it is best to use the total time in actual minutes spent, we do not "ding" the providers on an audit/review if they use the greater than 30 minutes statement.

I agree with Thomas in that I think some audit companies try to find/create mistakes to support extending their contract to providing education rather than being able to say the practice is doing a good job.

 

[Pathos]

Don't forget that we should first and foremost follow our coding guidelines as listed in the CPT book. Then we can adjust (if needed) to payer policies, as it is with Medicare and Consultation E/M codes. Also, don't forget that each MAC is tailored to certain regions and areas, meaning my local MAC (Noridian) is different than someone who lives in Florida, and you don't necessarily have to follow another MAC's guidelines.

I have seen this type of documentation both ways (actual time and "greater than 30 minutes"), and as mentioned above, I have never downcoded or seen a chart being downcoded because the discharge didn't include the actual time, but only the "greater than 30 minutes" statement instead. Perhaps the auditing company is using the regular time documentation rules, where actual time should be documented (greater than 50% of 30 minutes was spent on counseling...etc.), however since the CPT code explains "greater than 30 minutes", then I do not see the reasoning behind this type of downcoding. I would recommend getting concise feedback from the auditing company, and unless they have something from a firm and well trusted source than will hold up in an official audit (like RAC), then I would be very wary on this type of source.

Hope this is helpful!