May 6, 2022 | By Shannon DeConda, CPC, CEMC, CEMA, CPMA, CRTT
A great deal of time was spent this year with new coding updates focusing on critical care split shared updates, but not much time was given to all of the other red-lined updates in the critical care section of the CMS Claims Processing Manual. Let’s focus our attention today on the topic of Concurrent Critical Care.
Concurrent Critical Care is when members of the same group Tax ID and the same specialty both provide critical care to the same patient on the same calendar day. While we do see a sharing occur between physicians, we now see this has become a more common practice with the advancement of practicing midlevel practitioners in inpatient facilities. With this advancement came changes in how to report two providers sharing such encounters; in prior years, critical care was a service that could NOT be split/shared. A “workaround” was soon engineered, time permitting, in which one provider reported the primary critical care code, 99291, and the other provider reported the secondary critical care of 99292.
At the time this work-around was adapted, the rules were rather loosey-goosey and the only to find out about billing this way it was mostly word of mouth because there weren’t a lot of FAQs sent out saying, “Hey! We want to pay you to optimize your provider service by getting paid for using both. Here’s how to bill for concurrent critical care services.” Ha! Therefore, until now, the rules – well there weren’t really any published guidelines. Now, times, they are a-changing.
What it really comes down to is one main rule, beyond ensuring you are members of the same group, same specialty, etc… The time of BOTH CPT codes must be maxed out in order to report both codes.
Here is the excerpt from the Claims Processing Manual:
Once the cumulative required critical care service time is met to report CPT code 99291, CPT code 99292 can only be reported by a practitioner in the same specialty and group when an additional 30 minutes of critical care services have been furnished to the same patient on the same date (74 minutes + 30 minutes = 104 total minutes).
Notice the sum at the end indicating that when cumulative critical care is reported, 104 total minutes is required.
This will be a big change as previously there was NO such requirements in place. This update should be provided to Compliance Departments for updates and release to your organizations and policy revisions ASAP.
The update can be found on page 11 of the following link: https://www.cms.gov/files/document/r11288CP.pdf#page=9