Health Information Management

CMS proposes that hospitals must track critical care time

APCs Insider, August 25, 2006

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CMS proposes that hospitals must track critical care time

In the 2007 OPPS proposed rule issued August 8, CMS proposed a time threshold for reporting new critical care codes Gccc1 and Gccc2. This marks a major departure from their policy since the inception of the OPPS. You can read the rule in its entirety at the CMS Web site: http://www.cms.hhs.gov/HospitalOutpatientPPS/Downloads/CMS1506P.pdf

At the outset of the OPPS (p. 18452 of the April 7, 2000 rule), CMS states: "We believe it would be burdensome for hospitals to keep track of minutes for billing purposes. Therefore, we will pay for critical care as the most resource intensive visit possible as defined by CPT code 99291." It was clear that CMS intended for hospitals to report critical care when the patient met the definition of being critically ill or injured, but that the time requirement threshold did not apply.

However, in the new rule CMS appears to have copied the language of CPT codes 99291 and 99292 without recalling their previous guidance concerning the burden placed on hospitals while tracking time. The 30-minute time threshold for CPT 99291 applies to physician billing for their professional services. Under OPPS, the APC payment covers the hospital staff and facility resources expended during critical care services. Note that in the hospital setting, these resources are expended immediately, not after 30 minutes, and often involve three, four, or more staff attending to the patient simultaneously.

If CMS intended to impose a new time-based reporting requirement for hospital critical care, it did not define the documentation requirements or the basis to count time. For example, what time counts towards the definition of critical care? Why would the physician's time be the sole criteria for the hospital to report its significant staff resources expended for critically ill or injured patients?

Hospitals may want to consider asking CMS these and other related questions in comments to the proposed rule. The comment period closes October 10, 2006. If you choose to comment on CMS' proposed changes to critical care, click here: http://www.accessdata.fda.gov/scripts/oc/dockets/comments/commentdocket.cfm?AGENCY=CMS and select the CMS 1506-P link. Include the caption "Visits" at the beginning of your comment.



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