Radiologists perform Evaluation and Management (E/M) services and may bill for them. However, it is important to distinguish between a separate E/M service, and the interaction with the patient that is related to and inherent in a procedure provided on the same date of service. E/M services provided on the same day as a minor procedure are generally included in the procedure payment. A separate E/M code should be reported only if the E/M service is significant, medically necessary and unrelated to the decision to perform the minor procedure. The National Correct Coding Initiative Policy (NCCP) Manual states that the fact that the patient is new to the physician is not sufficient in and of itself to support an E/M code.
Documentation in the patient medical record must support the nature and level of the E/M service billed. Services performed to prepare for the patient visit, such as review of imaging reports, and services performed to complete the E/M service, such as writing prescriptions, are included in the reimbursement for the level of patient visit charged and not separately reported. Routine follow-up visits within the global period are included in the global surgical payment and not billed separately. No charges should be submitted to third-party payers for routine post-procedure visits during the global period unless the physician is part of the Medicare data collection project on global surgery, in which case the postop visit should be reported with code 99024.
According to the National Correct Coding Policy (NCCP) Manual, the global payment for a major procedure includes postoperative E/M services performed during the global period that are “related to recovery from the surgical procedure” or “related to complications of the surgery.” Postoperative visits that are not related to the surgical diagnosis or to a complication of surgery can be reported separately. Visits for post-procedure complications are not included in the CPT® definition of the global surgical package, but they are included in Medicare’s definition and should not be billed separately to Medicare. Visits for treatment of the patient’s underlying condition (not recovery from a procedure) and visits for unrelated conditions are separately billable. They should be submitted with modifier 24 (Unrelated evaluation and management service by the same physician or other qualified health care professional during a postoperative period). Note that modifier 24 is not required when the E/M service occurs after the global period ends.
Follow-up visits that occur after the end of the global period are separately billable. However, the services must be medically necessary and reasonable for the patient’s condition. Special billing rules apply when an E/M service is provided in conjunction with a procedure. In many cases, the E/M service is included in the procedure and should not be coded separately. And in those situations when it is appropriate to submit an E/M code, a modifier may be needed to indicate the relationship between the E/M service and the procedure. The relevant modifiers include modifier 24 for unrelated E/M service during the postop period, modifier 25 for significant separate E/M service on the same day as a procedure and modifier 57 for decision for surgery.
There are potentially many opportunities for practices to bill for E/M services, but it is important to ensure that there is sufficient documentation, medical necessity and corresponding submission of the appropriate type and level of visit. Taking the time to review your current practices will yield potential increased revenues and ensure compliance.
Melody W. Mulaik, MSHS, CRA, RCC, RCC-IR, CPC, COC, FAHRA, is the president of Revenue Cycle and Coding Strategies Inc.