POS for Hospital Services

Question:

We are wondering if you can help address a discussion in our office related to the coding rule changes for hospital services. CPT instructs to report 99221-99223 (inpatient hospital/observation) and 99231-99223 (subsequent hospital/observation) for both inpatient and observation services. Our hospital does not have a dedicated outpatient observation area; all patients are cared for on the inpatient division. We believe we understand this does not matter for code selection. Here is our question. What is the place of service for the observation patient on the inpatient division now that we are using the same code series?

Answer:

Yes, you understand the guidelines correctly related to the inpatient/observation codes and physical location- it is about admit status in this situation.  You will continue to report the appropriate code from the 99221-99223 and 99231-99233 based on the type of service and the location status of the patient.

If the patient has been admitted as an inpatient, regardless of where there bed is located, you will report the appropriate initial or subsequent hospital inpatient code and the place of service is 21 (Inpatient Hospital).

If the patient is in outpatient observation status (‘admitted’ to observation) you will report the appropriate initial or subsequent observation code and the place of service is 22 (On Campus-Outpatient Hospital (e.g. observation).

POS 19 would not be correct for the patient in observation status as this place of service isOff Campus-Outpatient Hospital.

Is an Annular Repair Separately?

Question:

Our physician stated he was told at his prior hospital that he could report an annular repair with a discectomy.  We have told him this was inclusive but he is asking us to contact KZA.   Is the annular repair reportable in addition to the discectomy code? If yes, what CPT code would we report?

Answer:

Thank you for your inquiry.  Your response was accurate; it is unfortunate when physicians are given inaccurate coding device. While the hospital may be able to bill for closure devices, the work of repairing the annular defect is inclusive to the physicians work. Report the appropriate discectomy codes (e.g. 63020-63030)

Retrocalcaneal Bursectomy

Question:

Our surgeon performed a repair of an Achilles tendon, excision Haglund’s deformity of the calcaneus and retrocalcaneal bursectomy. Are we able to code the bursectomy in addition to the repair and excision of Haglund’s? Thank you in advance for your assistance.

Answer:

Thank you for your inquiry and explanation of procedures performed. The excision of the retrocalcaneal bursectomy is not separately reportable. This work is inclusive to the excision of the Haglund’s deformity.

Shared Visits in the Hospital for Medicare

Question:

I have a question regarding 2023 shared visit rules. I am reviewing an E&M note where I will select the level of E&M based on the MDM being the substantive part and not time. My question: does each provider have to document their individual time if not a factor in the level of E&M I recommend?

Answer:

No, the documentation of time is not required if Time will not be a determining factor in E&M code selection.

CMS has delayed the implementation of Time as driver for defining the substantive part of the shared encounter until January 2024.

The following excerpt is from the Final Rule published in November 2022.

Page 212:
“..After consideration of public feedback, we proposed to delay implementation of our definition of the substantive portion as more than half of the total time untilJanuary 1, 2024. We continued to believe it is appropriate to define thesubstantive portion of a split (or shared) service as more than half of the totaltime, and proposed that this policy will be effective beginning January 1, 2024….”

You may consider working with your providers to start documenting time should CMS move forward with a final implementation of Time as the driver of substantive time in 2024. This would allow them to become familiar with including this in their notes, while informational at this time, if the code is to be selected on the MDM and not time..

Anterior and Posterior Labral Repairs

Question:

Our surgeon documented anterior inferior labral repairs and then documented posterior inferior repairs.  The surgeon wants to report 29806 x 2 and I do not believe that is correct.  Will you assist?

Answer:

Thank you for your question. You are correct in that CPT code 29806 may not be reported twice. You will report 29806-22 once that includes both labral repairs. Remember to increase your standard fee to signify this code is different than the traditional code (no modifier).

Costochondral Injection

Question:

We saw a patient who presented with chest pain and the physician diagnosed costal chondritis and the administered an injection into the costochondral junction. We are debating what CPT code to report for the injection? Is it 20550, 20600, 20605 or an unlisted code? We are considering CPT code 20600.

Answer:

Thank you for your inquiry. This is not your typical orthopaedic injection! From a CPT coding perspective, the correct code is CPT code 20605 when Ultrasound Guidance is not a component of the service. The diagnosis is M94.0 (Chondrocostal junction syndrome).

Note: This advice is based on guidance from the AMA’s CPT Knowledge Base, revised in 2015 (KB #5189). The specific Q&A is available through AMA subscription.