02/04/2023

Medicare’s “technical correction” on Critical Care & Meet our new Executive Assistant

Medicare’s “technical correction” on Critical Care found in the Physician Fee Schedule (PFS) Final Rule for 2023 has created headaches for more than one office billing from this series of codes.  It has also caused, for some offices, a change in the workflow for these time-based codes (992919292). 

In the 2022 PFS final rule, it was indicated that “if 75 or more cumulative total minutes were spent providing critical care, the billing practitioner could report one or more units of 99292”.  This erroneously indicated that just one minute past the 30-74 minutes of Critical Care code (99291) allowed you to bill for the add on 99292 code.  The 2023 PFS final rule states “we intended to state that CPT code 99292 could be billed after 104, not 75, or more cumulative total minutes were spent providing critical care”.  CMS stated that the correct identification of the time needed to bill a 99292 add on critical care code was stated in another section of the 2022 final rule in their defense. 

CMS POSITION:

There were comments made to CMS that this was a change in their billing policy.   CMS disagreed, reiterating that the code reads “each additional 30 minutes” as the time increment.  Their position was that they have always looked for providers to bill 99292 after 104 minutes.  So, to them, this was not a change.

More than likely, if your practice is billing for Critical Care, one of two scenarios needs to take place before claims are released.  Either there needs to be billing staff (not the providers) selecting codes or billing staff needs to confirm the appropriate assignation of any 99292 codes that providers are indicating. This will allow for staff to look at the total time of critical care documented to be sure the correct code was assigned based on that insurance’s rules.  Remembering that if they have Medicare or an insurance that is following Medicare rules (like some state Medicaid and other commercial carriers), a different amount of minutes is needed to bill a 99292 than the table found in your CPT book indicates.   

HOSPITALISTS & BILLING SOFTWARE:

Understand that this would not be caught in any front end edit by your clearing house, it would only be discovered on audit.  Another situation to be addressed is hospitalists and other employed providers who are using a billing software tied to their charting.  If they use a drop down field to document time for critical care and those minutes result in code assignment, the codes generated by most software systems will be based on CPT rules not CMS rules.   That could potentially lead to incorrect billing for time increments of 75 minutes or more for those following Medicare’s rules.   

CPT VS CMS ON TIME BASED CODES:

One final note on CPT vs CMS on time-based codes: analyze what your practice is doing with assigning prolonged care codes to Evaluation and Management (E\M) services.  These two entities also disagree on where time starts in this series of codes as well.   In this case CMS created ”G” codes (G0316, G0317, G0318) for their claims instead of the CPT codes 99417 and 99418.

WELCOME OUR NEW EXECUTIVE ASSISTANT:

ALYSSA RUFF!!

MMBA would like to share with our members, that we have found a new Administrative Assistant who will be assisting the Board and each of you when you email and or call the organization.  Please give a warm welcome to Alyssa Ruff. 

Alyssa Ruff is an RHIT graduate from Davenport University, with nearly 8 years of Outpatient Coding experience. She is extremely excited to be a new member of the MMBA team and grateful for the warm welcome she’s received as she’s transitioning into her new role.

Alyssa is blessed with a loving husband, a sweet one-year-old daughter, and two kitty fur babies. She enjoys playing volleyball, golfing, bowling, sewing, videogames and Dungeons & Dragons. Alyssa also writes poetry and is a polymer clay sculptor.

She is thankful for this tremendous opportunity within MMBA and is thrilled to be here to assist in any way that she can!

Alyssa’s life mottos are as follows:

“Be the woman that welcomes all people to her table to feel comfortable and accepted.”

 “Embrace the wildflower inside and grow unapologetically in unexpected ways.”