Evaluation and Management
Critical Care Services
How does a primary surgeon bill for critical care service(s) in the global surgery period when care is unrelated to the surgery?
Answer: Critical care may be billed in this situation by adding modifiers 24 and FT to the critical care service. Modifier FT is effective 1/1/2022 and required as of 3/1/2022. Documentation must clearly support the reason for the service as unrelated to the primary surgical event.
What is the correct way to report critical care when the continuous critical care time crosses midnight into the next calendar date? Example: “120 minutes of critical care, start time 11:00 p.m. on day one and continuing into day two from 12:00 a.m. until 1:00 a.m.”
Answer: These services would be appropriately billed as one unit of CPT code 99291 (first hour) and one unit of 99292, both billed on the initial DOS. As a reminder, billing for these services requires performance by an attending physician or hospitalist; services by residents are not billable to Medicare.
What type of documentation does NGS recommend to support subsequent critical care services (99292), in order to show the time spent was subsequent to the initial 30‒74 minutes?
Answer: After 74 minutes of 99291 have been performed and documented, additional care requiring 30 minutes or more of time may be represented by 99292, either contiguous with the 99291 or at a later point in time on the same date of service by the same provider or a group member. Time for each segment of care should be documented as either minutes spent (“60 minutes”) or clock time (“1:00–2:00 p.m.”).
What is the appropriate billing when a provider performs a critical care service on the same date as he/she performs an endotracheal intubation (CPT code 31500)?
Answer: The critical care service requires 30‒74 minutes of performance time, and any time spent performing a separately payable service (e.g., endotracheal intubation) must be deducted from the time counted toward the critical care service. If the critical care service, on its own, was of 35 minutes duration, and intubation was performed at a time before or after the critical care service, then the critical care code would be billed with a modifier 25, and the intubation code entered on another line of coding.
The billing providers in our critical care service may be an attending physician, NP or PA. They all bill under the same group/tax ID number. How do you report critical care services when both an NP and attending physician contribute to critical care service 99291?
Answer: Effective 1/1/2022, critical care services may be performed on a split/shared basis by physician and NPP members of the same group. Time spent by each practitioner individually may be aggregated toward total critical care time and the total time spent supports the billed service. Each provider must individually document his/her contribution to the critical care service and the service is to be billed by the provider who performed and documented the greater component of critical care time.
Episodes of continuing/subsequent critical care, represented by CPT code 99292 may be performed and billed by other group members, including NPPs.
Each line of service must clearly indicate the rendering provider’s identifying information, especially given the variation between MD and NPP reimbursement. This information would need to be provided in Item 24 or the electronic equivalent.
When two members of a group (either physician or NPP) perform and bill CPTs 99291 and subsequent episode(s) of 99292 on the same date of service, do both services have to be billed on the same claim?
Answer: When 99292 is billed on a separate claim, NGS claim editing logic reviews all claims for the same date of service as the primary code. When 99291 has been billed and allowed for that date of service, 99292 would be payable, if all other claim requirements were met. Although the NPI on the two claims will vary when the codes are performed by different group providers, the two services are payable to the group.
Is documentation of the exact time duration required in support of CPT codes 99291‒99292 or can the provider can check a box on the electronic record that prints out “Critical Care Time Spent: 30‒74 minutes.” Other documentation for medical necessity and services performed would of course be present.
Answer: Although CMS does not define specific time recording, NGS strongly recommends time spent rendering critical care services be included in the associated notes. The preferred format is “11:00‒11:45 a.m.” although “Time spent: 45 minutes” may also be acceptable.