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Is it compliant for a hospital to bill for conscious sedation (CPT 99141) when administered in the ED by a non-employed physician? We are currently using status indicator "N" on the bill and the hospital does provide nursing staff to monitor the patient.

Compliance Monitor, July 2, 2004

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When conscious sedation is administered in a hospital-based outpatient setting it should generally be billed irrespective of the employment status of the physician.

In order to be billed, the service must meet the CPT descriptor language, and be medically necessary and appropriately documented. It is not uncommon for procedures to be performed in the ED by specialists or other private physician and these should be billed for the facility in order to cover the costs of providing the service.

You are correct that the two conscious sedation codes have status indicators of N, services incidental; payment is packaged into another service or APC Group:

Although there is no relative weight or payment made for conscious sedation, Medicare collects data on all services provided. They've directed providers to continue to report these services even though they are packaged. The data is used to set APC relative weights and payment rates for the following year(s). In addition some payers may pay for the conscious sedation so it is important to report it on the claim.

This question was answered by Candace E. Shaeffer RN, MBA, RHIA, vice president Coding/Quality Management, Lynx Medical Systems, Inc.

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