NAMAS Webinar Q&A: Coding Updates for 2021, 12/15/2020

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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Thu Dec 17, 2020 2:25 pm

Below are the questions received during our recent webinar, Coding Updates for 2021, originally presented on December 15, 2020. These questions have been answered by the webinar presenter, Grant Huang, CPC, CPMA

Question 1:
On a recent webinar with one of the MACs with whom I work, it was stated that when a series of lab, for instance, INR to monitor Coumadin, is ordered, because each time it is done, it is billed with ONE UNIQUE CPT CODE, we can only credit the provider with ONE order (fine, I can live with that), and ONE review – I CAN’T LIVE WITH THIS.
INR testing, as you know, is done regularly and a medical decision made each time regarding dosing of Coumadin, so when this is done during an E/M (and it isn’t always), why would the provider not be credited for the review under the Data section? Have you heard anything like this from anywhere else? The other example is HgbA1C for diabetics; there may be a single order for quarterly testing, but each time a review is necessary so it doesn’t seem appropriate to not credit the provider for the review when done during an office visit.
Appreciate any feedback you have on this one.
Answer 1:
The AMA guidance is not clear on whether multiple instances of the same test can be credited as unique tests. Our interpretation would be that they can, as the same test administered on different dates would have different data in their results and different DOS to mark them as unique. The payer would be right to worry about the same batch of tests being “reviewed” every visit, but if you say they aren’t claiming MDM credit unless there is a dosing change or other alteration to the plan, then it would make sense to credit it. However, I haven’t heard of any clarifying language from any payer. I would run this by your MAC again to be sure. We are still in the very early stages of gathering payer-specific feedback and policies as many payers simply haven’t decided themselves what they will do.

Question 2:
Time based coding:
• Will residents, fellows time will count in during the daily encounter in total time?
• Split-shared visits – APRN – participation can be counted based on time instead of MDM?
• What happens if the MD will trying to use the time based coding for new patient but the visit encounter is less then 15 minutes?
Answer 2:
• Will residents, fellows time will count in during the daily encounter in total time?
• No, nothing changes as far as that goes. The time counted is the time of the teaching physician who is billing.
• Split-shared visits – APRN – participation can be counted based on time instead of MDM?
• This is not something CPT decides, it is going to be a matter of payer policy. First of all, split/shared visits using codes other than 99202-99215 do not change, and the time rules that currently apply, will continue to apply. If there is a scenario where you are able to apply split/shared billing in a hospital outpatient setting and are billing 99202-99215, CPT says you may count non-overlapping time and apply the 2021 guidelines… assuming the payer allows this.
• What happens if the MD will trying to use the time based coding for new patient but the visit encounter is less then 15 minutes?
• They need to support it on MDM, which shouldn’t be too difficult for a level 2 without any history or exam requirements.
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