Corporate Compliance

Note from Hugh

Medicare Insider, April 10, 2007

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CMS posted some significant questions and answers on their FAQ Web site this week.  The Q&As address the Type A/Type B distinction in emergency department coding (Id #s 8302-8310) and critical care and trauma response (Id #s 8311-8314). 


The Type A/Type B emergency department coding Q&As are quite interesting.  They contain much awaited further guidance on many questions related to the distinction between Type A/Type B emergency departments.  They deal primarily with "Fast Tracks", but there is also information regarding off-site provider based emergency departments or satellites.  


The Q&As discuss using actual hours of operation or purely physical space, in contrast to triage methods that differ by time of day, to determine whether an area is separately identifiable and should be coded as a Type A or Type B emergency department.  I would encourage any hospital that has a separate physical space in their ED, separate hours of operation for any portion of their ED or uses different staff or triage processes during distinction portions of the day to review the Q&As carefully to ensure they are billing Type A and Type B correctly. 


CMS also advises hospitals, at the end of each Q&A on the subject, that it may be necessary for them to consult their fiscal intermediary to determine which areas of their emergency departments are Type A and Type B. 


The critical care and trauma response Q&As primarily confirm recent clarifications in the OPPS Final Rule for CY2007 and the implementing transmittal. However, the answer to question 8311 again raises the idea that tracking and reporting time precisely for critical care is too burdensome for hospitals.  In fact, they seem to indicate that this is the rationale for packaging of the add-on code for additional 30 minute increments of critical care. 


Hospitals should note the answer does emphasize that a minimum of 30 minutes is required to code critical care (CPT code 99291) and reiterates the instruction to use an appropriate visit code, presumably an ED visit code, for critical care that lasts less than 30 minutes.


We are still waiting with bated breath for the IPPS proposed rule for FY 2008.  CMS has announced the availability of the MedPAR data once the display copy of the rule is posted, so we should see it posted anytime. 

~ Kimberly Anderwood Hoy, Esq.

Editor's Note: Kimberly Anderwood Hoy, director of Medicare and compliance for HCPro, Inc., is the author of this week's "Note from Hugh" in Mr. Aaron's absence.

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