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Thread: ER docs billing Radiology procedures

  1. #1

    Default ER docs billing Radiology procedures

    AAPC: Back to School

    I work for a group of Emergency doctors that read their own x-ray films from 5:00 PM to 8:00 AM. Within in the body of their dictation they use words such as "X-ray read and interpertated by myself". However the radiologist comes in the next day and read the film and bill for the reading and interpertation also. Is their a written rule that the emergency doctors should be the only one to bill for the reading and interpertation when results are given to the patients face to face at the time of visit.

  2. #2
    Join Date
    Apr 2007
    Louisville, KY


    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.
    Kevin B. Shields, RHIT, CPCO, CCS, CPC, COC, CCS-P, CPC-P, CPC-I

  3. #3


    If the radiologist interprets the report documented, a 26 modifier is needed. If technical component needs to be reimbursed as well, may be a ZS modifier can be given. But not all codes can be assigned this ZS modifier. Need to check on split billable services, etc.
    Take care.

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