Health Information Management

Do not include 73140 in E/M point system

APCs Insider, June 17, 2005

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Do not include 73140 in E/M point system

QUESTION: We are a hospital-based urgent care clinic. Our nurses have their imaging tech licenses. They perform simple x-rays, such has hand, finger, chest, etc. Sometimes the PA assists the nurses by treating the patients.

Since there is a charge for the x-ray--e.g., CPT 73140 for x-ray of the fingers--can the nurses also include "X-rays by RN: 20 points" in their level of care point system?  Generally, we don't include any procedures that generate charges included on the acuity tool that creates the "level of service" or "E/M level" for the facility. Can we consider x-rays procedures in the same vein as suturing and splinting?

ANSWER: Do not include separately billed and paid procedures in your facility's guidelines when determining E/M levels of care. CMS stated in the November 1, 2002 Final Rule, "We believe that, within constraints of clinical care and management protocols, the level of service for emergency and clinic visits should be determined by resource consumption that is not otherwise separately payable."

While CMS has not defined a national facility E/M coding system, their intent on this issue seems clear. In your example, if a patient meets the criteria for a 99282 visit, and you also allow "X-rays by RN: 20 points" in the level of care point system, this may cause the E/M level to move up to a 99283. If your hospital also bills the X-ray and is paid an APC for the X-ray, as well as the higher APC payment for the 99283, this could be construed as "double counting" the X-ray.

As a best practice, include those services that consume resources, but are not separately paid in addition to the visit E/M level in your level of care system.

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