Coding Cues: Answers to your questions about...

September 7, 2007

Choosing code levels; inpatient consults; blood draw station

Key Points

Choosing code levels

I'm a neurologist who regularly evaluates patients that other physicians send me. I generally submit higher level codes for the initial consult as well as for any subsequent visits. I feel that I can bill higher levels for my services because of my specialty and expertise. In addition, I always document a comprehensive history and exam for the established patient visits following the consults. A colleague tells me I'm not billing correctly. Is she right?

Yes. It's inappropriate to charge a higher level of care simply because of your specialty. It's also inappropriate to charge a higher level of care based solely on the documentation for history and exam. An established patient visit requires two of the three key components (history, exam, and medical decision-making).

Inpatient consults

An orthopedist asked me to evaluate the endocrine status of one of my patients who's in the hospital. I'd seen her three months ago in my office, and her diabetes was controlled. After I examined her in the hospital, I wrote my findings in the progress notes and dictated a consult note. I submitted an inpatient hospital visit, but a staffer said I should have reported a consultation. Should I have?

Yes, because it appears that you met all the criteria for a consult. You could submit the appropriate level of an inpatient consultation (99251-99255) if the request for your opinion is documented in the medical record, and you notate your services and findings in the progress and consult notes.

Remember, though, that only one inpatient consult can be reported per admission. If you need to see the hospitalized patient again, you'd submit a subsequent hospital code (99231-99233) for the visit.

Blood draw station

A large laboratory that I refer the majority of my patients to approached me with an offer to provide my practice with a "draw station," including supplies and a technician. The lab says I could bill a draw fee because the service is performed right in my office. When the technician isn't busy, he could assist my other staff. This sounds too good to be true. Is it?

It depends. You didn't say who'd bill the lab testing fees, or if you're paying for the supplies and technician. If the lab's billing the testing fees, and if you're paying for the supplies and technician at fair market value, then charging a draw fee appears to be appropriate. You could bill insurers that allow a separate charge for a blood draw. And Medicare will reimburse you as long as it's a legitimate practice expense. But if you're not paying for the supplies or the technician for the time he spends helping your staff, it could appear that the lab's providing an incentive for you to refer patients to it. Before committing to any deal, have a healthcare attorney review the arrangement for potential antikickback issues.

The author, vice president of operations for Reed Medical Systems in Monroe, MI, has more than 30 years' experience as a practice management consultant, as well as being a certified coding specialist, certified compliance officer, and a certified medical assistant.