I would recommend use of some resources in determining the appropriateness of your ER providers' processes.
A.) 2009 OIG workplan: page 7 talks a little on the scrutiny this area will receive--it includes interpretations. Go here for more information:
B.) American College of Radiology: Please review their General Radiology standards and guidelines. These provide information on what is considered a formal interpretation and the documentation requirements thereof.
C.) American College of Emergency Physicians: Here's some information on their recommendations:
Here's a snippet of some commentary:
"An emergency physician may bill for the interpretation and report of an X-ray for a Medicare patient when a 'complete written report similar to that prepared by a specialist in the field' is documented. CMS has not identified a specific documentation standard but states that the physician must include relevant clinical issues, comparative data, and study findings. To these three categories, the American College of Radiology Standard for Communication, Diagnostic Radiology has suggested the addition of a description of the procedure and materials, any limitations, and clinical impression, conclusion, or diagnosis. CMS has not expressly adopted these specific suggestions.
A separate written report, although a fully distinct document, is not required by CMS. However, some Medicare carriers have independently established more restrictive criteria."
I hope this offers you some clarity.
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