Question when do we count independent review of scans?

wynonna

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MD orders sinus CT scan on 7/1/21. MD is in our office.
A different MD from our office interprets this same CT scan on 8/15/21 so it falls under "interpretation of a test performed by another MD".
Does the CT count for 1 point on 7/1 when it was ordered? meaning 1 point only?
Or does it count for Category 2 "Independent Interpretation of tests" on 8/15 when it was interpreted?
thank you
 

csperoni

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If the 2 physicians are from the same practice and the same specialty they are counted as they are 1 physician; you may not count either the order or independent interpretation. The payment of the actual test itself reimburses for that work.
If the physicians are the same practice, but different specialty, you may count 1 point for the CT order. You may only count independent interpretation if the ordering MD also reviews the images (not just the report) and provides their own report or summary of the findings.
 

wynonna

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Hello, and thank you:
For clarification, CT scan is being done and billed by radiology at hospital, not our office. Do we count test on day it is ordered, or on day the imaging is reviewed and interpreted after the report becomes available? I know for counting purposes, we are usually allowed to go with what is more advantageous to the practice. For example, in choosing TIME or MDM, whichever is the higher level.
Or, phrased another way, under what circumstances can we count imaging for our own provider for "independent interpretation of imaging" when he interprets and summarizes a scan and documents on his record his own findings?
In other words, when a PA orders a CT scan, but our MD interprets the imaging, also known as films, 2 days after it's ordered. This is Category 2 box under Data Review so when can we count points under this category?
We are in the outpatient office setting.
thank you
 
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csperoni

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When you are ordering and reviewing an outside test, you count it the day ordered and review is included.
If your physician is doing a separate independent interpretation, that is counted on the visit it is documented. Your physicians may practice differently, but my physicians never read the actual images and interpret the scan. Occasionally they will look at a couple of slices of a CT, but are not meeting independent interpretation.
Independent interpretation: The interpretation of a test for which there is a CPT code and an interpretation or report is customary. This does not apply when the physician or other qualified health care professional is reporting the service or has previously reported the service for the patient. A form of interpretation should be documented but need not conform to the usual standards of a complete report for the test.
In your example, it is unclear if the MD interpreting the imaging 2 days later is done as part of a return E/M. If it's not, then I don't think you may count it toward the prior E/M. I have not seen guidelines with this specific timing question, but I don't see how you could credit services at the PA visit that have not yet been provided.
 

wynonna

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Ok. Thank you. I thought we could count independent review when a scan is ordered externally, by ER or PCP, and we do the interpretation independently.
I also thought we could count for independent interpretation when: the scan is ordered at a prior visit by our PA, patient goes to get scan done, results become available, the radiologist issues a report. Then the patient comes back for a separate E&M. In this visit our MD does his own interpretation of the scan and not just reading the report. He wants to see all the details within the film himself to discuss with the patient. All this he documents.
Can he count Category 2: "independent interpretation of test performed by another MD or qualified health care professional"?
 

csperoni

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Yes, if an outside clinician ordered the scan and your physician views and interprets the images at a visit and provides interpretation, you may definitely count independent interpretation. I personally do not know of any physicians who practice that way and they will typically defer to the radiologist's reading. It may be more common in different specialties.
When your own clinician ordered the scan, I am not aware of any guidance that specifies this exact scenario. It feels like partial double dipping if you are already counting the order, and then also counting independent interpretation as the order includes review. However, at the time of the PA visit (when ordered), you do not know the physician will be providing independent interpretation a few days later. It's a gray area unless someone else is aware of official guidance. If this is something your office does on a regular basis, I would want official guidance. You may want to try contacting whatever organizations exist for your specialty for clarification if you cannot find it in CMS guidance.
 

wynonna

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Thank you so much Christine. We are ENT and our surgeon also has skills in interpreting Scans. So he likes to review them personally, since his review provides more details. He also reviews in part if he needs info from scan to plan surgery to excise a mass. We order many sinus scans for sinusitis and others for OSA and still other MRI and CT's for neck, tongue, and auditory canal masses.
thank you again.
 
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