David Stern, MD, CPC
Q. We are a fairly new urgent care center and could use
some help on E/M coding. I have read on various urgent
care websites that we can bill each visit as a new patient
visit (as long as it isn’t a follow-up to an existing problem). Can
you please give me some direction on where I can find this information?
A. What you are referring to is “problem-based coding.”
Never code in this way unless you have clearly communicated
with the payor about this method. Problem-based
coding is one way for urgent care centers to receive appropriate
compensation for the additional expenses incurred in providing
urgent care services. You can access an article on this
subject at: http://www.ucaoa.org/info/resources.html (click
on “problem-based coding”).
Q. We are starting an urgent care clinic. Should we bill
using place-of-service (POS) -11 (office) or POS-20 (urgent
care facility)?
A. In this situation, CMS defines an officeas “[a] location,
other than a hospital, skilled nursing facility (SNF), military
treatment facility, community health center, state or local
public health clinic, or intermediate care facility (ICF), where
the health professional routinely provides health examinations,
diagnosis, and treatment of illness or injury on an ambulatory
basis.”
An urgent care facility is defined as “[a] location, distinct
from a hospital emergency room, an office, or a clinic,
whose purpose is to diagnose and treat illness or injury for
unscheduled, ambulatory patients seeking immediate medical
attention.”
Of course, if you are operating a facility that would meet the
UCAOA definition of an urgent care center, then POS-20 would
be the most accurate code to use.
In coding, there is a general rule to use the most accurate
code to describe the services rendered. In the case of place-ofservice
codes, another common rule comes into play. This
rule is what I sometimes jokingly refer to as the “make-surethat-
you-give-the-payors-what-they-want” rule. Some payors
will refuse to pay on the POS-20 code. Others may have their
computers set up to only accept POS-20 from your center.
In some cases, payors will accept either code. Some payors
may use POS-20 to trigger a rule to allow problem-based coding.
Others never allow problem-based coding. For Medicare,
each fiscal intermediary is different—some require POS-20
and others want you to use POS-11. You must determine the
preference of your fiscal intermediary, or your claims will be denied.
Some payors cannot tell you which code you should
use, but they will deny any claims submitted from your center
with POS-11.
This has been a source of 100% denials for at least one urgent
care center in dealing with one particular payor. The
payor was unable to tell the urgent care center what the reason
was for the denials. After six months of having every single
claim denied, the urgent care center tried using POS-20;
and, voila, suddenly rejections ceased and their claims were
processed and paid.
So, you can see some payors may not even be aware of their
own software rules for place-of-service codes for your urgent
care center.
Q. We saw a patient for bronchopneumonia and the
physician removed an ear wax impaction on the same
visit. We coded a 99213 (level 3 E/M code), 69210 (removal impacted
cerumen), and 71020 (two-view chest radiograph). Payment
for the E/M code was denied. Why?
A. Code 69210 should have been attached to the diagnosis
for impacted cerumen (380.4) and the chest radi-
ograph code should have been attached to the code for bronchopneumonia
(485).
The E/M should have been attached to the ICD-9 code for
bronchopneumonia (485), with or without the code for impacted
cerumen (380.4). The E/M code should have been
modified with modifier -25.
Generally, this coding should result in payment, because
these codes do not have work components that overlap. Assuming
that you coded as noted, however, your payor may have
expected modifier -59 on some of the services to indicate
that these services were distinct procedural services.
As always, the coding consultant caveat applies, “Check
with the payor to understand the payor requirements.”
Q. Patients sometimes mistakenly use our urgent care
center for visits that are true emergencies, such as myocardial
infarctions. In those cases, we are equipped to provide
oxygen therapy to the patients. What is the code for administering
oxygen in our urgent care center?
A. In the hospital setting, reimbursement for these
types of expenses is included in reimbursement for
the facility code. All codes for physician services in the office
setting, however, include a component to include practice
expenses. That is generally why facility codes are not
billed in addition to other codes for services rendered in an
urgent care center.
Among other items generally included as bundled into practice
expenses are syringes, dressings, drapes, and surgical
trays and syringes. Many payors are coming to recognize that
true urgent care centers do incur expenses that are above and
beyond the practice expenses incurred in simple physician office
setting. Thus, many payors are reimbursing for these additional
expenses by reimbursing physicians for the code
S9088 (services rendered in an urgent care center).
Q. Our urgent care center saw a patient with a 2 cm laceration
caused by contact with a grinder in a factory.
The wound was grossly contaminated with grease and metal
filings, so the physician removed the metal filings and performed
extensive scrubbing and irrigation of the wound, and
sutured the wound with a single-layer closure.
We submitted a claim coded with 12001 (simple repair of superficial wounds of scalp…and/or extremities…2.5 cm or less).
Four days later, the doctor rechecked the wound and found it
to be infected. The wound was reopened, irrigated clear of pus,
and dressed. The patient returned daily for wound checks, packing,
and redressing for three days.
Medicare denied payment for all rechecks. What can we do
to get paid for these recheck visits?
A. This wound repair code has a 10-day global period.
Medicare defines the global period as covering all related
services during the global period, with the exception of
complications that require a visit to the operating room.
Under CPT rules as published by the AMA, however, “Postoperative
complications, exacerbations, and recurrences are not
included in the surgical package and should be reported separately.
Postoperative complications include conditions such as
wound dehiscence, infection, and bleeding.” Thus, it is legitimate
to bill payors for such complications.
Of course, some payors may choose to follow CMS guidelines
in this situation and may refuse to reimburse you for services
rendered to treat the complication. Make sure that you add
a diagnosis code to indicate the specific complication when you
are billing for services rendered to treat the complication.
One caveat applies to this specific situation: Because the initial
closure of the wound involved extensive cleaning and removal
of particulate matter, the wound closure should be
coded as 12031 (“Layer closure of wounds of scalp…and/or extremities…
2.5 cm or less”).
Yes, even though the wound was not a “layer closure” and
was closed with a single layer of sutures, AMA defines the “intermediate”
wound closure codes to include, “single layer closure…
if the wound is heavily contaminated and requires extensive
cleaning or removal of particulate matter.”
Now, aren’t you glad that you read to the end of the column?
That one point could pay for your annual subscription to JUCM.
(OK, I know it is free, but even if they charged $500, this point
would pay for itself.)
Note: CPT codes, descriptions, and other data only are copyright 2007 American Medical Association. All Rights Reserved (or such other date of publication of CPT). CPT is a trademark of the American Medical Association (AMA).
Disclaimer: JUCM and the author provide this information for educational purposes only. The reader should not make any application of this information without consulting with the particular payors in question and/or obtaining appropriate legal advice.
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David Stern is a partner in Physicians Immediate Care, with nine urgent care centers in Illinois and Oklahoma, and chief executive officer of Practice Velocity (www.practicevelocity.com), a provider of charting, coding and billing software for urgent care. He may be contacted at
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