READERS CONTINUE to have billing questions about post-discharge admissions, team conferences and the propriety of copying and pasting. Here are some questions along with my responses.
A doctor I am billing for holds a team conference once a week to discuss a patient or patients. Should I be billing 99367 (medical team conference in which a physician spends 30 minutes or more, not face-to-face with the patient and/or family) for each patient discussed?
Before physicians can bill for team conferences, they must meet specific criteria. First, they must have a medically necessary reason. If there has been no change in the patient’s condition nor any changes in a patient’s plan of care, it may be hard to make the case that a weekly team conference is medically necessary.
Just because patients are in a critical care unit does not mean they qualify for critical care.
Next, as per the CPT guidelines, a team conference must consist of members of specific disciplines who all contribute to the discussion and to a patient’s care plan—and who have treated that patient on a regular basis. Team conferences must include a minimum of three different types of providers, all of whom have seen the patient face-to-face within the past 60 days for services other than a team conference.
Each provider must also be able to bill for the team conference in accordance with her or his scope of practice in that particular state—and must document his or her involvement in the conference. If the required providers are not present or if they don’t all meet these criteria, no one can bill a team conference code.
More on billing a post-acute admission
I read your article about billing discharge services (“Steer clear of copy and paste,” June) and I have a question: Say my partner discharges a patient from the hospital and I then bill for an admission to a nursing home.
Can we both bill our individual services? What if I’m doing the nursing home admission from the hospital?
I am going to assume you are referring to a Medicare patient. In most cases, Medicare views physicians from the same group and within the same specialty as a single physician. It will not pay for two evaluation and management services provided by the same physician on the same date of service.
But in the case of a hospital discharge service and an admission to a nursing facility on the same date, Medicare may pay for those two services when provided by a single physician (or physicians of the same group practice and specialty who are viewed as a single physician). That’s as long as one of the doctors isn’t a surgeon admitting the patient to a nursing home for a surgery-related condition that would be covered by the global period.
The pertinent language, which is from the Medicare Internet-Only Manual 100-4, chapter 12, section 184.108.40.206, notes that Medicare Administrative Contractors (MACs) now “pay the hospital discharge code (codes 99238 or 99239) in addition to a nursing facility admission code when they are billed by the same physician with the same date of service.”
And it doesn’t matter whether you technically do the nursing home admission at the nursing home or in the hospital. In either case, the bill for the admission should note the appropriate place of service, which for a nursing home means a designation of 32.
Copy and paste, and critical care
I am an auditor for critical care providers in a hospital. My question: When physicians have copied from notes two days before (a critical care note!) and add only a one or two word update, can we give them credit for a whole assessment and plan? Moreover, only one diagnosis plan was updated.
Although you provide only limited details, I too am concerned that a patient’s condition, plan or care had so few changes that a note could be copied, almost verbatim, from one 48 hours prior. That’s particularly worrisome for a critically ill patient. Remember, a critically ill patient must be at significant risk for sudden deterioration leading to death.
Just because patients are in a critical care unit does not mean they qualify for critical care. Medicare has published a great deal about billing for critical care services, and here are two resources: the CMS Medicare Internet-Only Manual 100-4, chapter 12, section 30.6.12, and MLN Matters article 5993. Even CPT goes to great lengths to explain what a critically ill patient looks like from a clinical perspective.
I think that your instincts are right; it is not a sound practice for a provider to “copy and paste” notes for a patient who is critically ill. But as an auditor, you can’t assume that the physician didn’t do the work and only copied a previous note.
I’d suggest discussing your concerns with the physician or the department’s medical director. Until the medical director provides some guidance, you will have to allow the copy and pasted notes, if that’s what they are, as part of your overall determination of level of service.
Sue A. Lewis, RN, CPC, PCS, has more than 40 years of health care experience.
Published in the December 2019 issue of Today’s Hospitalist