Health Information Management

Q/A: Billing for ED services that cross days

APCs Weekly Monitor, October 9, 2009

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Q: Patient arrives in ED September 7 at 23:00. ED clinical staff initiate an IV push and hydration September 8 at 00:30. Should we bill September 7 as the date of service (DOS) for the visit and September 8 as the DOS for the drug administration? Or should we bill all services on September 7, the date the patient arrived in the ED?
 
A: Bill both the visit and the drug administration service on September 7 because both are billab;e under ED revenue code 045X. The Medicare Claims Processing Manual, Chapter 4, Section 180.6 discusses this, although not very clearly. The manual discusses billing other services such as laboratory and radiology on the date rendered. However, it is vague with respect to services billed under ED revenue code 045X other than the ED encounter itself.
 
The implementing transmittal, Claims Processing Transmittal 1151 (published in 2007) more clearly states: “Hospitals report ER services under the 045X revenue code with a line item date of service (LIDOS) indicating the date the patient entered the ER”.

Also, CMS officials specifically stated during hospital open door forum calls that any services under the 45X revenue center should be billed the date the patient arrived at the ED along with the encounter.

They cited as an example a patient who arrived at the ED October 1 and received an injection October 2. CMS officials instructed listeners to bill both the ED services and injection on October 1. Presumably, this policy is intended to ensure proper application of NCCI edits. The pertinent coding policies apply per encounter and require billing services that are part of an encounter spanning more than one date of service on the same date for proper application of the edits.



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