Good morning,
Thank you for your work on this topic. The changes are very positive for the actual practice of critical care medicine.
In reading through the CMS document on proposed changes to 99291 and 99292 (pages 451 and 452) the excerpt below which makes it unclear to me whether vascular access procedures now
MUST be billed as part of critical care time
OR whether the time to perform them must simply be excluded from critical care services:
"We proposed to adopt CPT's listing of bundled services that are part of critical care visits: interpretation of cardiac output
measurements (CPT codes 93561, 93562), chest X rays (CPT codes 71045, 71046), pulse
oximetry (CPT codes 94760, 94761, 94762), blood gases, and collection and interpretation of
physiologic data (for example, ECGs, blood pressures, hematologic data); gastric intubation
(CPT codes 43752, 43753); temporary transcutaneous pacing (CPT code 92953); ventilator
management (CPT codes 94002-94004, 94660, 94662);
and vascular access procedures. As a
result, these codes would not be separately billable by a practitioner during the time-period when
the practitioner is providing critical care for a given patient. We also proposed to adopt the CPT
prefatory language stating that time spent performing separately reportable procedures or
services should be reported separately and should not be included in the time reported as critical
care time. "
In CMS response to comments they state:
"We note that we included vascular access procedures in the list of bundled services
because page 31 of the CPT Codebook states that vascular access procedures
are included incritical care bundle when performed during the critical period by the physician(s) providingclinical care. Therefore, we are finalizing as proposed the CPT listing of services bundled into
critical care. We will review and consider any future changes made by CPT to the listing of
bundled services, if future changes are made by the CPT Editorial Panel.
After consideration of public comments, we are finalizing our proposal to adopt the CPTdefinition of critical care services and the current CPT listing of bundled services."
Does anyone from the group know if CMS will continue to allow separate billing of these procedures
if the time used to perform these procedures is not counted toward critical care time? Are we now
mandated to bill all vascular access procedures as part of our critical care time?
Thank you for your work here.
Sean Josephs, MD, FCCM
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Sean Josephs
University of Cincinnati College of Medicine
Cincinnati OH
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