Secondary Payor Doesn’t Recognize Consultations

Question:

We have a patient with 2 commercial payers (BCBS and Cigna). A consultation code was submitted to BCBS, and they paid according to our contract. However, Cigna is refusing to process the claim since they no longer pay for consult codes. Am I allowed to change the CPT code and rebill Cigna? Or would I need to change the CPT, refile to the primary as a corrected claim, then send the balance on to Cigna?

Answer:

We suggest calling CIGNA and ask how they want this handled according to their policies. WithMedicareyou have two options: (1) bill the appropriate category and level of service documented (e.g., for outpatient consults [99202-99215] or inpatient consults [99221-99223]) or (2) bill the consultation code, which will result in a denial of payment from Medicare and appeal on paper explaining the situation.

*This response is based on the best information available as of 11/2/23.

E&M Coding Based on Time

Question:

Our physicians’ default to time for almost every office encounter. We are working with them on documentation and what work contributes to total time and what does not. They perform procedures such as nasal endoscopy, sinus debridement, laryngoscopy, etc. in the office. They are counting the total time spent with the patient, including these activities and we do not believe that is correct. Can you help?

Answer:

Thank you for your inquiry. We will not address the default to time for almost every encounter other than to say medical necessity must be present for time spent. That said, the activities you identify are billable services represented by other CPT codes (aka are separately reported) and may not contribute to the total time in the billed Evaluation and Management (E/M). In other words, the procedure time must be deducted from the total time, assuming the E/M service is reportable.

*This response is based on the best information available as of 10/19/23.

Modifier Order on CMS Claim Form

Question:

We are submitting a hospital claim form with the modifier 25 and FS modifier. We are unsure which modifier to list first. What is your recommendation?

Answer:

Thanks for contacting KZA and remembering to use the FS modifier for shared services provided in the hospital. KZA recommends placing the modifier 25 first, as this is considered a reimbursement modifier followed by the FS modifier, which is an informational modifier.

*This response is based on the best information available as of 10/5/23.

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 until January 1, 2024. We continued to believe it is appropriate to define the substantive portion of a split (or shared) service as more than half of the total time, 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.

*This response is based on the best information available as of 08/17/23.

Allergy Injections

Question:

After a physician has signed off an order for the administration of allergy injections, is he/she required to sign off on each allergy injection administered by his staff?

Answer:

Allergy immunotherapy is not under the diagnostic guidelines but rather the incident to guidelines. The physician should provide direct supervision and the physician should indicate a review of the allergy injection schedule during follow-up. A guideline has not been published indicating that the physician must sign off on each individual injection.

*This response is based on the best information available as of 08/03/23.

Allergy Testing Help

Question:

What is the daily maximum allowable unit for CPT 95017 [Allergy testing, any combination of percutaneous (scratch, puncture, prick) and intracutaneous (intradermal), sequential and incremental, with venoms, immediate type reaction, including test interpretation and report, specify number of tests] by Medicare in 2023?

Answer:

The MUE’s (medically unlikely edits) for 2023 IS 27.

*This response is based on the best information available as of 07/20/23.