David Stern, MD, CPC
Q. Many procedures, such as injections and fracture
care, are reported to patients as “surgery.”
Patients sometimes accuse us of false billing, as they
don’t consider these procedures to be a “surgery.” How
can we fix this problem?
A. All third-party payors have installed computer software
programs that have code descriptions loaded
for each CPT code. Many of these code descriptions are hard
to understand, and sometimes they are not truly accurate.
Getting payors to come up with more accurate and patient-
friendly code descriptions is likely to take many years.
When patients express concern, you will need to educate
them to them on this issue.
You may want to give your staff a script to follow. An example
script might be, “Although many procedures are not
accurately described as ‘surgeries,’ the insurance company
may have that word loaded into their software program.
They often use the term ‘surgery’ for many procedures that
do not involve a trip to an operating room nor a skin incision.”
You may even offer to read or mail the patient the actual
description from the CPT manual, as published by the AMA.
Q. My new urgent care will be performing multiple
procedures, including suturing lacerations, conscious
sedation, and casting fractures. Since I am not a
specialist, should I use different codes to report procedures
performed in an urgent care center?
A. All physicians use the same CPT, ICD-9, and HCPCS
codes for the same procedures, diagnoses, and supplies.
However, some payors do pay more for the same procedure
—or even the same evaluation-and-management (E/M)
codes—if the procedure (or E/M) is performed by specialty
physicians. Medicare pays the same amounts for a procedure,
regardless of the specialty the physician. With other
payors, it is not uncommon to offer a fee schedule at a 20%
to 30% premium for specialty physicians.
Some urgent care centers have become accredited
through UCAOA and have been able to obtain contracts as
physicians specializing in urgent care medicine. However,
they often encounter significant obstacles in receiving recognition
as specialty physicians by payors.
Q. Do I have to use a preventive-care E/M code for
a patient visit when the patient does not have a
chief complaint? An example would be a patient who
has hypertension but does not have any symptoms.
A. A chief complaint is required for physician office
E/M codes (99201-99205). For the asymptomatic patient,
you can simply note the problem; for example, “Patient
presents for a chief complaint of hypertension….”.
Q. How would I document a history of present illness
(HPI) for a patient who has an asymptomatic
problem, such as hypertension or elevated blood
sugar? How could I document the duration, location,
modifying factors, associated symptoms, quality, timing,
context, and severity?
A. Per the 1995 or 1997 E/M coding guidelines, you can
note when the problem first started (i.e., duration);
under the associated symptoms, you could note that the
problem is currently asymptomatic.
Under 1997 E/M coding guidelines, you can get credit
toward the HPI in past medical history under the chronic/
inactive problems. If you note one chronic/inactive problem
and its status, you get credit toward a brief HPI. If you note
at least three chronic/inactive problems and the status of at
least three chronic/inactive problems, you get credit toward
an extended HPI.
Q. Can I use the established patient E/M code 99211
for medication refills performed by a nurse?
A. A medication refill by itself is not a separately coded
service. If you only provide a simple medication refill,
then no E/M code is appropriate. If the clinical staff provides
an additional, medically necessary E/M service beyond
the medication refill, you may use code 99211.
Make sure that the clinical staff documents the actual E/M
service in the chart. A simple note with the patient vitals and
documentation of the refill is not adequate, as you must
specify the additional E/M service that was provided.
For example, it is appropriate to document side effects of
a medication, the clinical staff’s discussion with a physician,
and the recommendation for follow-up.
Q. Is it ever appropriate to bill a level-IV E/M code
for a visit that does not have a documented
physical exam?
A. In some circumstances, it may be appropriate to
code a 99214 without a physical exam, as an established
patient E/M is based on the three elements of the
E/M—i.e., history, physical exam, and medical decision-making
—but with the established patient E/M, the lowest of the
three elements is dropped and the next highest element determines
the actual code.
Thus, it is possible to drop the physical exam from the E/M
algorithm and document only the history and medical decision-
making; the code is determined by the lowest level of
the history and medical decision-making.
With a new patient E/M, however, the lowest element is
not dropped from the algorithm; instead, the lowest element
of the history, physical exam, and medical decision-making
actually determines the level of code.
In other words, when basing the E/M code on these three elements,
it is not possible to compliantly code a level-IV new patient
E/M code (99204) without documenting a physical exam.
It may, however, be compliant to code a level-IV new patient
(or established patient) E/M without a physical exam
if more than half of the total face-to-face time between the
patient and the provider involved counseling and/or coordination
of care. If coded by time, the total face-to-face time
of a 99214 is 25 minutes; the total face-to-face time for a
99204 is 60 minutes.
Make sure that you document the total face-to-face time,
and specify that more than half of the time was devoted to
counseling and/or coordination of care. In addition, make
sure you describe the nature of the counseling.
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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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