NAMAS Webinar Q&A: Auditing Prolonged Services

Post here your questions regarding auditing ,coding, documentation, and compliance. Also, join in on the conversation- help your fellow auditors and compliance professionals in the industry.

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Wed May 22, 2019 4:00 pm

Below are the questions received during our recent webinar, Auditing Prolonged Services, originally presented on May 22, 2019. These questions have been answered by the webinar presenter, Stephanie Allard, CPC, CEMA, RHIT.

Question 1:
What type of documentation would you expect to see for billing non face to face prolonged services 99358/99359? Can these codes be used for chart review, revewing labs and calling the patient before or after an office visit to discuss results for pulmonary HTN patients? The test results are extensive and take a lot of time with the patient on the phone.
Answer 1:
For the documentation I would expect to see the date the work was done, total time spent, start and stop time and a free texted explanation as to why it was medically necessary and exactly what was done.

The code can be used if extensive chart review is done, so again this is where it is important for the provider to free text an overview of what they reviewed and not say something simple like "reviewed chart".

As far as the telephone situation goes, I do not think this is going to apply without difficulties from an external auditor if it gets to that point. I would not use it at all for a call with the patient before a visit because it would be questioned why they just did not discuss face-to-face. As far as using this for a call after a visit I still think this is a catch 22 situation, in order to bill for non face-to-face the provider would have to spend a minimum of 31 minutes. If they are on the phone that long the medical necessity could be questioned as to why that patient was not brought in for another face-to-face visit and if the patient is brought in because the problem is extensive and requires a face-to-face to discuss the result, diagnosis and treatment options then why was time spent on the phone? The other thing to think of and remember is that this is to be a rare occurrence so if the provider is doing this often that would potentially be a red flag to bill for telephone calls int his way which are otherwise not reimbursable. I would suggest the patients coming back for a follow up if the time spent is excessive enough to support 31+ minutes.
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