CODING Q&A
Addressing Problem-based
Coding and Other Challenges
■ DAVID STERN, MD, CPC
Q .
We are a fairly new urgent care center and could
use some help on E/M coding. I have read on var-
ious urgent care websites that we can bill each visit as a
new patient visit (as long as it isn’t a follow-up to an ex-
isting problem). Can you please give me some direction
on where I can find this information?
What you are referring to is “problem-based coding.”
Never code in this way unless you have clearly com-
municated with the payor about this method. Problem-based
coding is one way for urgent care centers to receive appropri-
ate compensation for the additional expenses incurred in pro-
viding urgent care services. You can access an article on this
subject at: http://www.ucaoa.org/info/resources.html (click on
“problem-based coding”).
A. Q .
We are starting an urgent care clinic. Should we
bill using place-of-service (POS) -11 (office) or POS-
20 (urgent care facility)?
In this situation, CMS defines an office as “[a] location,
other than a hospital, skilled nursing facility (SNF), mil-
itary treatment facility, community health center, state or local
public health clinic, or intermediate care facility (ICF), where
the health professional routinely provides health examinations,
diagnosis, and treatment of illness or injury on an ambulatory
basis.” An urgent care facility is defined as “[a] location, distinct
from a hospital emergency room, an office, or a clinic,
whose purpose is to diagnose and treat illness or injury for
unscheduled, ambulatory patients seeking immediate med-
ical attention.”
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.practicevelocity.com), a provider of charting, coding
and billing software for urgent care. He may be contacted
at dstern@practicevelocity.com.
w w w. j u c m . c o m
Of course, if you are operating a facility that would meet the
UCAOA definition of an urgent care center, then POS-20 would
be the most accurate code to use.
In coding, there is a general rule to use the most accurate
code to describe the services rendered. In the case of place-of-
service codes, another common rule comes into play. This
rule is what I sometimes jokingly refer to as the “make-sure-
that-you-give-the-payors-what-they-want” rule. Some payors
will refuse to pay on the POS-20 code. Others may have their
computers set up to only accept POS-20 from your center.
In some cases, payors will accept either code. Some payors
may use POS-20 to trigger a rule to allow problem-based cod-
ing. Others never allow problem-based coding. For Medicare,
each fiscal intermediary is different—some require POS-20
and others want you to use POS-11. You must determine the
preference of your fiscal intermediary, or your claims will be de-
nied. Some payors cannot tell you which code you should
use, but they will deny any claims submitted from your center
with POS-11.
This has been a source of 100% denials for at least one ur-
gent care center in dealing with one particular payor. The
payor was unable to tell the urgent care center what the rea-
son was for the denials. After six months of having every sin-
gle claim denied, the urgent care center tried using POS-20;
and, voila, suddenly rejections ceased and their claims were
processed and paid.
So, you can see some payors may not even be aware of their
own software rules for place-of-service codes for your urgent
care center.
Q .
We saw a patient for bronchopneumonia and the
physician removed an ear wax impaction on the
same visit. We coded a 99213 (level 3 E/M code), 69210
(removal impacted cerumen), and 71020 (two-view chest
radiograph). Payment for the E/M code was denied. Why?
Code 69210 should have been attached to the diagno-
sis for impacted cerumen (380.4) and the chest radi-
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