CODING Q&A How to Define a Type B ED—and Other Vexing Questions ■ DAVID STERN, MD, CPC T he urgent care practitioner may not live by coding alone, but proper reimbursement depends on it. To that end, Dr. David Stern, a certified coder who is in great demand as a speak- er and consultant on coding in urgent care, will offer answers to commonly asked questions in every issue of JUCM. In this issue, he addresses a potpourri of issues raised by urgent care practitioners. Q. A consultant tells us that we have to use the new codes for type B emergency departments. We are owned by the hospital, but are off campus and do not advertise ourselves to be an emergency department. Are we a type B emergency department? There has been a lot of confusion about type B emer- gency departments this year. Some consultants have been telling urgent care administrators that they are a hospital- owned urgent care center, so they are a type B emergency department. Simply being hospital owned, however, is not adequate to meet the specific criteria outlined by the Centers for Medicare & Medicaid Services (CMS). To be a type B emergency department, your center must meet one of the following criteria: Ⅲ It is licensed by the state in which it is located under applicable state law as an emergency room or emer- gency department. [Unless your center is licensed as an emergency department, this does not apply.] Ⅲ It is held out to the public by name, posted signs, adver- tising, or other means as a place that provides care for emergency medical conditions on an urgent basis without requiring a previously scheduled appointment. [Rarely does A. David Stern is a partner in Physicians Immediate Care, with nine urgent care centers in Illinois and Oklahoma, and chief executive officer of Practice Velocity (www.prac- ticevelocity.com), a provider of charting, coding and billing software for urgent care. He may be contacted at dstern@practicevelocity.com. 34 an urgent care clinic hold itself out to the public as treating “emergency conditions.” Rather, almost all urgent care cen- ters tell the public specifically that their centers are not appropriate for evaluating or treating true emergency condi- tions. Instead, most urgent care centers tell the public to go to a hospital emergency department or to call 911 if the problem is thought to be a true emergency.] Ⅲ During the calendar year immediately preceding the cal- endar year in which a determination under this section is being made based on a representative sample of patient visits that occurred, at least one-third of all outpatient vis- its to the urgent care center are for the treatment of emergency medical conditions on an urgent basis without requiring a previously scheduled appointment. [Very, very few urgent care centers treat over one-third of their patients for true emergency conditions. Some hospital emer- gency departments may not even meet this criterion.] Very few urgent care centers will meet any of the above three requirements, and thus they should not be classified as type B emergency departments. Some confusion may arise from the third criterion. There are three parts, however, to this final criterion, and your center must meet the definition in all three parts (not just one or two parts) to qualify as a type B emergency department. So, if we evalu- ate all three parts, the question is this: Are over 1/3 of the vis- its to your center: Ⅲ on an urgent basis Ⅲ without appointment Ⅲ and for treating emergency medical conditions? Many urgent care centers may answer “yes” to the first two components, but for the majority of true urgent care cen- ters, the answer to the last question is almost always “no.” Hence, they do not qualify as type B emergency departments. Q. We frequently remove cerumen from the ears of patients in our urgent care center. We use differ- ent methods for removing the cerumen, including irriga- JUCM T h e J o u r n a l o f U r g e n t C a r e M e d i c i n e | Fe b r u a r y 2 0 0 7 w w w. j u c m . c o m