Billing and Documentation

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  • 1.  Any updates on this topic?

    Posted 10-20-2021 10:31
    Has there been any further discussion with CMS or other updates to this topic?

  • 2.  RE: Any updates on this topic?

    Posted 11-03-2021 06:42
    Good news!
    It appears most if not all of our concerns were addressed by CMS.We are reviewing the recently released document and will discuss it at a future meeting but it appears our concerns around disallowing critical care billing during global surgical period, disallowing E&M on the same day as critical care(due to clinical deterioration) and defining groups have all been addressed in a positive manner.

    See link below to the document.Caution: 2400 + pages! Key critical care areas are between pages 449-464.

    Thank you all for your advocacy efforts and support.


    Piyush Mathur
    The Cleveland Clinic
    Cleveland OH

  • 3.  RE: Any updates on this topic?

    Posted 11-03-2021 08:57
    The coordinated response from SCCM was strongly supported by the work of this group.  Well done!  The feedback that we provided to CMS dovetailed with that of other organizations.  While I hope that we do not have future challenges in this space, I am confident that we are well prepared to meet it!

    Lewis Kaplan
    Professor, Surgery
    Perelman School of Medicine, U of Pennsylvania
    Philadelphia PA

  • 4.  RE: Any updates on this topic?

    Posted 11-03-2021 12:01

    Indeed, great work by SCCM and your team in raising awareness and leading the response to these proposals.  I have shared the document and outcome with my local critical care groups. We will need to stay aware of when they implement those -55 and -54 modifiers. 

    Cherylee Chang
    Professor; Division Chief, Neurocritical Care
    Duke University Medical Center

  • 5.  RE: Any updates on this topic?

    Posted 11-16-2021 08:08
    Edited by David Carpenter 11-16-2021 08:08
    Here are my takeaway points:
    The final rules include several important policy changes for critical care clinicians:   
    • Critical Care  
      • Shared (split) billing is allowed for critical care.  
      • Follow-up care – when medically necessary, physicians or APPs in the same specialty and same group may provide follow-up care on the same calendar day.  
      • For follow-up care, if one practitioner does not meet the time reporting requirements for 99291, the time may be aggregated with other providers.   
      • Concurrent Critical Care - When medically necessary, critical care services can be furnished concurrently to the same patient on the same day by more than one practitioner representing more than one specialty.  
      • Critical Care and E/M services - In limited circumstances, CMS will allow critical care and E/M services billed on the same day (critical care after other E/M services).   
      • Critical Care unrelated to the procedure is allowed during the global surgical period.  
      • Critical care that is continuous and crosses midnight will be reported on the day the encounter started.  
    • Split (shared) services  
      • Split (shared) services are now allowed for new and existing patients.   
      • For 2022, split (shared) services non-critical care encounters can be billed based on either completion of a key component or the practitioner that reports the greater amount of time.  
      • Split (shared) billing is allowed for critical care services. The bill may be submitted for individual practitioners based on time or the time may be submitted under the provider proving the substantive portion of the time.  
      • CMS will create a separate identifier for split (shared) services.  
      • For split (shared) services, the physician and APP must be in the same group, but CMS has not further defined group.   
    The important points:
    1. Documentation for shared billing requires date time stamps for both providers.
    2. Shared billing E/M can be billed by time so the attendings need to document time for these encounters. 
    3. CMS declined to go forward with their proposal to bundle critical care into the global period. 
    4. Critical care that is continuous and crosses midnight is reported on the day the critical care started. 

    David Carpenter
    Emory University Hospital
    Atlanta GA