Friday, May 24, 2019 | Nicole Knight
Impending coding and documentation changes by CMS and the American Medical Association (AMA) have been sparking conversations lately. Physicians, Administrators, Coders, etc. are asking us how these changes could impact cardiovascular services and how to prepare for them.
According to a recent announcement, the AMA is planning to simplify Evaluation and Management (E/M) service codes and documentation requirements in the 2021 CPT® book. The AMA has published impending changes including deleting CPT® code 99201, removing the requirement to document the amount of history and number of examination elements, and changing the basis for E/M code selection to focus on the level of medical decision making performed or the total time spent performing the service on the day of the encounter. This follows the initiatives by CMS to revamp E/M services that started in 2018 and continue to evolve.
All of the buzz has me thinking about how important documentation for time-based billing is and how Cardiovascular providers are often reluctant to use time as a driving factor.
Coding based on time is expanding beyond E/M service codes with virtual, remote patient monitoring, prolonged care, etc. It’s time to evaluate your time-based coding and documentation effectiveness, evaluate training needs, and plan for future opportunities.
Here are a few things to start looking at:
CMS stresses codes 99358 and 99359 cannot be reported during the same service period as complex chronic care management (CCM) services or transitional care management services. They are not reported for time spent in non-face-to-face care described by more specific codes having no upper time limit in the CPT code set.” CMS further stipulates, “99358 and 99359 can only be used to report extended qualifying time of the billing physician or other practitioner (not clinical staff).” Codes 99358 and 99359 are time-based and include “the total duration of non-face-to-face time spent by a physician or other qualified health care profession on a given date providing prolonged services, even if the time is not continuous,” according to CPT®. Documentation should summarize the necessity and specific content of the prolonged services.
Despite warnings and disclaimers to the contrary, time is central to the E/M coding system. Though it may not always determine what code is selected for the primary E/M service, it does play an important role in selecting the appropriate code for prolonged services, for services that involve extensive counseling or coordination of care, and for time-dependent codes. A better understanding of the rules on the basis of time will help providers secure fair compensation for all the services they provide.
Nicole Knight, LPN, CPC, CCS-P, ACS-CA, is Vice President, Revenue Cycle Solutions and Consulting at MedAxiom. Her decades of hands-on health care experience includes cardiology and neurology practice operations, clinical management, business office management, and consulting for coding and compliance. Nicole maintains her LPN licensure in Louisiana and Florida. She is a member of the American Academy of Professional Coders and the American Health Information Management Association. She received her Advanced Coding Certification with the Board of Medical Specialty Coding. Nicole is a certified AHIMA ICD-10-CM Trainer and completed a Lean Sigma Healthcare training course at Johns Hopkins University. She also serves on the Physician Practice Council for AHIMA.
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