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Ensure separate billing of Type A vs. Type B ED patients

APCs Insider, February 9, 2007

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Ensure separate billing of Type A vs. Type B ED patients

QUESTION: I am seeking clarification on how to identify Type A and Type B ED services. For example, a hospital may have its main ED open 24 hours a day, seven days per week, but have another area either within the ED or down the hall which is open only 10 a.m. to 10 p.m. This is important now that CMS has created separate G-codes for billing Type B ED visits.

ANSWER: Type A EDs, which are available to provide services 24 hours a day, seven days per week, must meet one or both of the following requirements related to the Emergency Medical Treatment and Active Labor Act (EMTALA) definition of a dedicated emergency department. Specifically, a Type A ED must:

1. Be licensed by the state in which it is located under the applicable state law as an emergency room or ED; or
2. Be held out to the public (by name, posted signs, advertising, or other means) as a place that provides care for emergency medical conditions on an urgent basis without requiring a previously scheduled appointment.

CMS believes that hours of operation significantly impact hospital resource costs, which is why they have differentiated between Type A and Type B departments.

In the 2007 OPPS final rule, a facility questioned whether a Type A emergency department that has a separate adjacent space that is organizationally part of the Type A emergency department, but treats less severe patients and is often closed at night, would be eligible to bill using Type A emergency department visit codes.

CMS's response was as follows:

Where a hospital maintains a separately identifiable area or part of a facility which does not operate on the same schedule (that is, 24 hours per day, 7 days a week) as its emergency department, that area or facility would not be considered an integral part of the emergency department that operates 24 hours per day, 7 days a week for purposes of determining its emergency department type for reporting emergency visit services. Instead, the facility or area would be evaluated separately to determine whether it is a Type A emergency department, Type B emergency department, or clinic.

CMS expects hospitals with separate areas to evaluate the status of those areas and bill accordingly. In general, it is not appropriate to consider a satellite ED or an area of the ED as available 24 hours a day simply because the main emergency department is available 24 hours a day. In most instances, the facility should "carve out" these portions of the emergency department that are not available 24 hours a day, and bill these visits with Type B emergency department codes. Consider designating a different patient type for these areas to facilitate tracking in your hospital.

Facilities should also consider establishing separate and distinct E/M guidelines to correspond with the new G-codes (G0380-G0384) CMS has provided for use in a Type B emergency room.

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