Coding for evaluation and management (E/M) services has gotten a lot more complicated over the past few years. From descriptor changes to code deletions, you may take longer than usual to code a hospital encounter. Your best bet in these situations is to consult the inpatient coding guidance straight from payers.
Check out three common inpatient coding questions, along with answers directly from insurers to help guide your code selection.
Question 1: How Should We Report Observation Care Now?
When CPT deleted the observation care codes last year, many coders have been flummoxed about how to report services that are documented as observation care or that take place in the hospital’s observation unit. But you can still bring in reimbursement for those services as long as you look to the inpatient E/M codes. However, unlike in the past, there isn’t one set solution. The code you select will be based on whether the encounter was initial or subsequent, and which day discharge occurred.
In black and white: Part B MAC Novitas Solutions cleared up this issue in its Observation Care Services Part B Fact Sheet:
“For dates of service on and after January 1, 2023, observation services are billed by the admitting physician using:
- Initial hospital inpatient or observation care: 99221-99223
- Subsequent hospital inpatient or observation care: 99231-99233
- Hospital Inpatient or Observation Care Services (Including Admission and Discharge Services): 99234-99239
- Hospital Inpatient or Observation Discharge Services: 99238-99239”
For instance, if you see a patient in observation care for 40 minutes and it’s an initial visit, report 99221 (Initial hospital inpatient or observation care, per day, for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and straightforward or low level medical decision making. When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded.)
Question 2: Do We Have to Record Start and Stop Times for Critical Care?
As most coders are aware, critical care is a time-based code, and if you don’t have documentation of how much time the provider spent on the patient’s case, you should not report 99291-99292. However, what confuses many providers and coders about this aspect of inpatient coding is how to document that time. While some believe they only need to document total time, others believe the medical record must contain start and stop times. In reality, while you must only record total time, payers do prefer start and stop times.
In black and white: “The time documented in the medical record must reveal a total time using either minutes or start and stop times (preferred),” said Part B MAC Novitas Solutions in its Evaluation and Management FAQs document.
Question 3: When Reporting Initial Hospital Care, Can We Bill Other E/Ms for Prior-Day Services?
Because the initial hospital care codes (99221-99223) aren’t explicit about what can be included to select the code level, many coders are confused about whether an earlier encounter with the same patient on the same day (but in another setting) should be billed separately or included in the hospital care code. Fortunately, Medicare payers have made it clear that you should roll those prior-day services into your initial hospital care code during inpatient coding.
In black and white: “If patient is admitted to the hospital during an encounter in another setting (i.e. physician office, nursing home, emergency room) and on the same date of service as the admission all E/M services provided by that physician in conjunction with the admission are considered part of the initial hospital care,” said Part B MAC CGS Medicare in its 99223 Fact Sheet.
You’ll use the documentation from the multiple encounters to select the most appropriate initial hospital care code.
Whether you’re coding for inpatients or outpatients, you need the latest E/M guidance. Expert Dreama Sloan-Kelly, MD, CCS, CPC, can help during her latest training, Collect $16 More Per E/M Visit in 2024 With Key Tips. Register today!
Check out our Coding and Billing Playlist on YouTube for the latest expert advice, and subscribe to our YouTube channel for step-by-step guidance!
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