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Billing and Coding in Neurology and Headache
Stuart B Black MD, FAAN
Chief of Neurology
Co-Medical Director: Neuroscience Center
Baylor University Medical Center at Dallas
CPT Codes vs. ICD Codes
CPT CodesCategory 1 CPT Codes
Describe a procedure or service identified with a five-digit numeric CPT code and descriptor nomenclature
Used to report physician services: medical, surgical, radiology, laboratory, anesthesiology and E/M
There are approximately 298 E/M CPT codes (99201-99499)
Category 11 CPT Codes
Optional codes developed principally to support performance measurement
PQRS is reported using Category 11 CPT Codes
Category 111 CPT Codes
Temporary codes for emerging technology, services and procedures
ICD Codes▫ Describe signs, symptoms, injuries, diseases and conditions▫ Describes the clinical condition of the patient to support the medical necessity or the
procedure or service (to describe the medical necessity of the CPT code chosen)▫ There are 17,000 ICD-9 Diagnosis Codes
Commonly Used CPT CodesWhen Time Matters
992129921399214992159920499205
10 minutes15 minutes25 minutes40 minutes45 minutes60 minutes
40 minutes45 minutes55 minutes70 minutes75 minutes90 minutes
85 minutes85 minutes100 minutes115 minutes120 minutes135 minutes
Code Typical Time for Code Threshold to bill 99354 Threshold to bill 99355
New Patient Evaluation 99201 - 99205
Established Patient Evaluation 99211 - 99215
Prolonged Service with Direct Patient Contact 99354 - 99355
If the time equals or exceeds the threshold time for code 99354 , but is less than the threshold time for code 99355, bill the E&M code and 99354.
If the time equals or exceeds the threshold time for code 99355 by no more than 29 minutes, bill 99354 and one unit of code 99355. One additional unit of 99355 is billed for each additional 30 minutes extended duration
Prolonged Service With Direct Patient ContactCase Examples of Using 99354 and 99355
Visit CPT code 99213 (15 min). Total duration of face to face service was 65 minutes. Bill CPT code 99213 and one unit of 99354 (Threshold 45 Min)
Visit CPT code 99212 (10 min). Face to face service was 35 minutes. Cannot bill for prolonged services because the 99354 threshold of 40 minutes was not met
Visit CPT code 99215 (40 min). Face to face service was 75 min of Counseling. Bill CPT code 99215 and one unit of 99354 (Threshold 70 min)
60 minute office visit that was Counseling: Cannot code 99214, which has a typical time of 25 minutes, and one unit of 99354. For Counseling and Coordination of Care, must bill the highest level code in the CPT code family (99215 which has a 40 minutes time units associated with it). If the additional time spent beyond 99215 is 20 minutes and does not meet the threshold time for billing prolonged services (60 minutes with a threshold for 99215 of 70 minutes) can only bill a 99215.
CPT Evaluation and Management CodingNew Patient (3 out of 3)
Code History Exam Medical Decision
Making
99201 Problem focused Problem focused Straightforward
99202 Extended problem
focused
Extended problem
focused
Straightforward
99203 Detailed Detailed Low complexity
99204 Comprehensive Comprehensive Moderate Complexity
99205 Comprehensive Comprehensive High Complexity
CPT Evaluation and Management CodingEstablished Patient (2 out of 3)
Code History Exam Medical Decision
Making
99211 Minimum services; Physician not required
99212 Problem focused Problem focused Straightforward
99213 Extended Problem
Focused
Extended Problem
Focused
Low complexity
99214 Detailed Detailed Moderate Complexity
99215 Comprehensive Comprehensive High Complexity
Defining Evaluation/Management ServicesSeven Components Recognized
1. History
2. Examination
3. Medical Decision Making
4. Nature of the Presenting Problem
5. Consultation
6. Coordination of Care
7. Time
Example CaseHistory: HPI, ROS, PFSH
32 year old woman with PMH of “TTH”. Onset of H/A age 14. H/Aassociated with vomiting, photophobia & dysfunction. The initialheadaches were left hemicranial. 8 year history of chronic dailyheadaches. The headaches are debilitating with a pounding,throbbing quality. Taking hydrocodone/acetaminophen daily(4-6/D) for 5 years; was taking butalbital beforehydrocodone/acetaminophen. Disability for 2 years. New onset:“visual blurring” OD; hypalgesia and possible mild paresis in RUE;transient confusion
Key Components of the HPI
HPI
Elements
(8)
LevelsProblem
Focused
Expanded
Problem
Focused
Detailed Comprehensive
•Location
•Quality
•Severity
•Duration
•Timing
•Context
•Modifying
factors
•Associated
signs or
symptoms
Brief
1-3 elements
Brief
1-3 elements
Extended
4 or more
Elements
Extended
4 or more elements
CategorizationNeurological Single System Examination
1 point General Appearance of Patient1 point Measurement of Any 3 or 7 Vital Signs1 point Ophthalmologic Examination
Cardiovascular Examination1 point Examination of Carotid Arteries1 point Examination of Heart1point Examination of Peripheral Vascular System
5 points possible Higher Cortical Functions8 points possible Cranial Nerves1 point Sensation1 point Muscular Strength1 point Muscle Tone1 point Deep Tendon Reflexes1 point Coordination1 point Gait and Station
Health Care Financing Administration. Documentation Guidelines for Evaluation and Management Services. Chicago, Ill: American Medical Association; 1997
Components of Neurological Examination
Level of Exam 1997 Single Organ System
Problem focused 1-5 elements
Expanded Problem Focused At least 6 elements
Detailed At least 12 elements
Comprehensive Perform all components
Document all elements in
Constitutional
Eyes
Musculoskeletal
Neurological
Document 1 element in
Cardiovascular
Billing and Coding in Neurology and Headache
Level of Care99201?; 99202?; 99203?; 99204?; 99205?
Physical Exam Exam: 25 Bullets
BP 210/105; Pulse 72 Irreg.; RR 15; General Exam: Carotids and PE WNL
Neurological Exam
Higher Cortical Function; Cranial Nerves; Motor; Coordination; Gait; Reflexes
Sensation; All WNL
Medical Decision Making
CPT coding provides only descriptive assessments, not numerical values CPT gives no precise quantative standards of measure, for the MDM elements
butMDM asks us to define a quantative assessment using qualitative descriptorsHowever, there are no quantitative values to define the elements of MDM
The MDM Elements Are
The number of diagnosis or management options The amount of data reviewed or orderedThe complexity of data reviewedThe complexity of data orderedThe risk of the presenting problemThe risk of diagnostic procedures oThe risk of management options selected
Medical Decision Making Scoring System
Methodology to determine level of MDM have been developed. There are several systems currently in use.
The scoring guides are based on a point system that takes qualitativeinformation collected by the provider and translates it into quantitative data.More points translate into a higher level of service.
Examples of the scoring systems that follow can be found in the CMS Evaluation And Management Coding and Documentation
Reference Guide and other reliable sources
In general scoring systems are not part of the 1995 or 1997 Evaluation and Management Documentation Guidelines
Medical Decision Making1. Number of Diagnosis and Management Options
Quotes from the 1997 Documentation Guidelines (CMS)
“For each encounter, an assessment, clinical impression, or diagnosis should be documented. It may be explicitly stated, or implied in documented
decisions regarding management plans and/or further evaluation.”
“For a presenting problem with an established diagnosis the record should reflect whether the problem is: a) improved, well controlled, resolving or resolved;
or inadequately controlled, worsening, or failing to change as expected.”
“For a presenting problem without an established diagnosis, the assessment may be stated in the form of differential diagnosis
or as a ‘possible‘, ‘probable‘, or ‘rule out‘ (R/O) diagnosis”
Health Care Financing Administration. Documentation Guidelines for Evaluation and Management Services. Chicago, Ill: American Medical Association; 1997
Case ExampleMDM Does Not Ask For The Final ICD Diagnoses
Level of Care99201?; 99202?; 99203?; 99204?; 99205?
Physical Exam Exam: 25 Bullets
BP 210/105; Pulse 72 Irreg.; RR 15; General Exam: Carotids and PE WNL
Neurological Exam
Higher Cortical Function; Cranial Nerves; Motor; Coordination; Gait; Reflexes
Sensation; All WNL
Diagnosis 1. Migraine with aura; 2. Chronic Daily H/A; 3.Medication Overuse Headache; 4.
Hypertension; 5. R/O Cardiac Arrthymia; 6. R/O CNS Mass Lesion; 7. R/O
Cerebral Vascular Disease (TIA, Cerebral Emboli, Infarct)
2. Number of Diagnosis and Treatment options >4
Medical Decision Making2. Amount and/or Complexity of Data to be Reviewed
Data to be reviewed includes: Ordering tests: Reviewing tests and discussion with physicians interpreting tests; direct review and interpretation of actual images, tracings specimens.
Old Records: It also includes obtaining old records for review and documentation of actual findings in the old records.
Document any tests ordered or data reviewed
The type of diagnostic testing ordered, planned, scheduled or reviewed
Review old medical records, lab, radiology and diagnostic tests
Discussion of the case or tests with another physician
Direct visualization of imaging or other tests
Case Example
Level of Care99201?; 99202?; 99203?; 99204?; 99205?
Physical Exam Exam: 25 Bullets
BP 210/105; Pulse 72 Irreg.; RR 15; General Exam: Carotids and PE WNL
Neurological Exam
Higher Cortical Function; Cranial Nerves; Motor; Coordination; Gait; Reflexes
Sensation; All WNL
Diagnosis 1. Migraine with aura; 2. Chronic Daily H/A; 3.Medication Overuse Headache; 4.
Hypertension; 5. R/O Cardiac Arrthymia; 6. R/O CNS Mass Lesion; 7. R/O
Cerebral Vascular Disease (TIA, Cerebral Emboli, Infarct)
2. Number of Diagnoses and Treatment Options >4
Complexity of
Data Reviewed
Reviewed >4
22 pages of prior records; Head Ct without contrast (2004); CT cervical spine
(2004); EEG (2005); MRI Head (2005)
Ordered >4
MRI Head with contrast; Lab; EKG; Cardiology Consult; Hospital Care?
Medical Decision Making3. RISK
What is meant by “Risk?”Risk of significant complications, morbidity, and/or mortality
Issues to consider and Documentation RecommendationsRisk associated with the presenting problemRisks associated with the diagnostic procedure(s)Risks associated with the possible management problems
Medical Decision Making3. Risk of Complications and/or Morbidity or Mortality
The Table of Risk is published in the 1997 Documentation Guidelines
Risk of the Presenting Problem(s)
Risk of Diagnostic Procedure(s) Ordered
Risk of Management Options
“The assessment of risk of selecting diagnostic procedures and management options is based on the risk during and immediately following any
procedures or treatment.”
“The highest level of risk in any one category (presenting problem(s), diagnostic procedure(s), or management
options) determines the overall risk.”
Health Care Financing Administration. Documentation Guidelines for Evaluation and Management Services. Chicago, Ill: American Medical Association; 1997.
Case Example
Level of Care99205
Physical Exam Exam: 25 Bullets
BP 210/105; Pulse 72 Irreg.; RR 15; General Exam: Carotids and PE WNL
Neurological Exam
Higher Cortical Function; Cranial Nerves; Motor; Coordination; Gait; Reflexes
Sensation; All WNL
Diagnosis 1. Migraine with aura; 2. Chronic Daily H/A; 3.Medication Overuse Headache; 4.
Hypertension; 5. R/O Cardiac Arrthymia; 6. R/O CNS Mass Lesion; 7. R/O Cerebral
Vascular Disease (TIA, Cerebral Emboli, Infarct)
Complexity of Data
Reviewed
Reviewed
22 pages of prior records; Head Ct without contrast (2004); CT cervical spine (2004)
Ordered
MRI Head with contrast; Lab; EKG; Cardiology Consult; Hospital Care?
Risk NPP: “…a disease, condition, illness, injury, symptom sign, finding, complaint or other
reason for the encounter, with or without a diagnosis being established at the time of the
encounter”
Using Table of Risk:
“One of more chronic illnesses with chronic exacerbation, progression or side effects of
treatment”
“Abrupt change in neurologic status; seizure, TIA, weakness, sensory loss”
“Drug therapy requiring extensive monitoring for toxicity”
MDM: Qualitative Data into Quantative DataTwo of the Three Components Determine the final Level
Table A1 (and A2)Number of Diagnosis and Management OptionsAdd up the points for the totalMay use the larger of Table A1 or A2 for total MDM
Table BData Reviewed or OrderedAdd up the points for the total
Table CLevel of RiskThe final Risk is the highest of the three Risks from the Table of Risks
Table DFinal level of MDMRequires that two of the three components are met or exceeded
CMS E&M Coding and Documentation Reference GuideTables A1 and A2
Table for Management Options: Table 1A
Examples of commonly prescribed treatments
One (1) point value is the most common designation for most treatments.
Table 1A, Number of Diagnoses is most commonly used
Number of Diagnoses and Management Options: (Table 1B)
Difficult to have specific table that is all inclusive for Management Options
“Continue the same therapy” or “no change in therapy” do not count unless specific therapy is described, documented or reviewed.
Drug doses for current medications are not required, however, the record must reflect conscious decision making to make no dose changes in order to count for coding purposes.
Medical Decision Making Scoring SystemTable A1:Number of Diagnoses or Treatment Options.
Number of Diagnoses or Treatment Options Points
Each new or established problem for which the diagnoses and/or
treatment plan is evident with or without diagnostic confirmation1
Two plausible differential diagnoses, comorbidities or complications
(not counted as separate problems) clearly stated and supported by
information in the record: requiring diagnostic evaluation or
confirmation2
3 plausible differential diagnoses, comorbidities or complications (not
counted as separate problems) clearly stated and supported by
information in the record: requiring diagnostic evaluation and
confirmation3
4 or more plausible differential diagnoses, comorbidities or
complications (not counted as separate problems) clearly stated and
supported by information in the record: requiring diagnostic evaluation
and confirmation4
Total 4
Management Options: Table A2Table A2 could never by all inclusive; following are examples
Do not count as treatment option’s notations such as: “Continue same therapy “ or “no change in therapy” if specific therapy is not described 0
Drug management includes “same therapy” or “no change ≥3 new/current meds In therapy if specific therapy is described. The record mustreflect conscious decision-making for coding purposes >3 new/current meds
1
2
Physical therapy, occupational or speech therapy 1
IV fluids, such as infusion in infusion center 1
Conservative measures such as rest, diet, etc 1
Discuss case with another physician or admit to hospital 1
CMS E&M Coding and Documentation Reference GuideTable B: Data Reviewed or Ordered
Order and/or review medically reasonable and necessary clinical laboratory procedures
1-3 procedures≥4 procedures
1 point 2 points
Order and/or review medically reasonable and necessarydiagnostic imaging studies in Radiology section of CPT
1-3 procedures≥4 procedures
1 point2 points
Order and/or review medically reasonable diagnostic procedures in Medical section of CPT
1-3 procedures≥4 procedures
1 point2 points
Discuss test results with performing physician 1 point
Discuss case with other physician(s) involved in patient’s care or consult another physician; does not include referring patient to another physician for future care 1 point
Order and review old records. Record type and source must be noted. Must be tied to patient care protocol
No summaryWith summary
1 point2 points
Independent visualization & interpretation of image/ test for MDM. Each visualization & interpretation is a point 1 point
Review of physiologic monitoring or testing data. 1 point
Total points 4 points
CMS E&M Coding and Documentation Reference GuideTable C:Risk of Complications &/or Morbidity or Mortality
1. Minimal (level 1) 2.Low (level 1 3. Moderate (level 2) 4 high (level 3)Final Risk determined by highest of 3 components below
Risk of presenting problem(Risk of morbidity, mortality, comorbidities, or complications with prolonged functional impairment)
1. min 2. low 3. mod 4. high
Risk of diagnostic procedure(s) ordered or reviewed
1. min 2. low 3. mod 4. high
Risk of management options selected
1. min 2. low 3. mod 4. high
Table D: Assignment of Medical Decision Making2 of 3 components in table D must be met or exceeded
A. Number of diagnoses or management options
1 PointMinimal
2 PointsLimited
3 PointsMultiple
≥4 PointsExtensive
B. Amount and complexity of data reviewed / ordered
≥1 PointNone/Minimal
2 PointsLimited
3 PointsMultiple
≥4 PointsExtensive
C. Risk Minimal Low Moderate High
Type of Medical Decision Making Straight-Forward
Low Complexity
ModerateComplexity
HighComplexity
CPT Evaluation and Management CodingNew Patient (3 out of 3)
Code History Exam Medical Decision
Making
99201 Problem focused Problem focused Straightforward
99202 Extended problem
focused
Extended problem
focused
Straightforward
99203 Detailed Detailed Low complexity
99204 Comprehensive Comprehensive Moderate Complexity
99205 Comprehensive Comprehensive High Complexity
Consultation and Coordination of CareTIME
In certain circumstancesTIME
Is the controlling factor in determining the level of an E/M service
“Intraservice times are defined as face-to-face time for office and other outpatient visits…”
The amount of time spent becomes the sole determining factor of the level of the E/M code
This is true of the exam and MDM components which do not need to be performed
Billing and Coding in Neurology and Headache
Time determines the level of E/M service when counseling and/or coordination of care
dominates > 50% the encounter
Counseling and coordination is separate from the history, physical exam and medical decision making
Consultation and Coordination of Care is a common scenario for Established Patient visits for Neurologists and
Headache specialists
The extent of consultation and/or coordination of care must be documented in the medical record independent of the
three key components
Consultation and Coordination of CareTime
Counseling patient and/or family documention (2013)Diagnostic results, impressions, and/or recommended studies
Prognosis
Risks and benefits of management or treatment options
Instructions and /or follow up
Importance of compliance with chosen treatment and management options
Instructions and/or follow-up
Risk factor Reduction
Patient and family education
Note on ‘Average Times’ For Consultation and Coordination of Care Times listed in the CPT code book are “average times” associated with
each CPT code. Auditors often treat them as threshold times
Ex: A 99214 has an average time of 25 minutes. Although not in the
Documentation Guidelines, an auditor usually interprets 25 minutes or
more supporting 99215, but less than 25 minutes not supportive of 99214
American Medical Association. Current Procedural Terminology CPT 2007. Chicago, Ill: AMA press;2013
Billing and Coding in Neurology and Headache
American Headache Society (AHS) AHS’s Headache Coding Corner
http://www.americanheadachesociety.org/professionalresources/AHSsHeadacheCodingCorner.asp
American Medical Association CPT-related resources
http://www.ama-assn.org/ama/pub/category/3113.html
Centers for Medicare and Medicaid Service (CMS) Evaluation and Management Services Guide
http://www.cms.hhs.gov/MLNProducts/downloads/eval_mgmt_serv_guide.pdf
1997 Documentation Guidelines for Evaluation and Management Serviceshttp://www.cms.hhs.gov/MLNEdWebGuide/25_EMDOC.asp