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DAVID STERN, MD (Practice Velocity)
Q.In one of your articles concerning the S9088 code (services provided in an urgent care center), you

 indicate this code cannot be billed to Medicare or Medicaid. However, I read in another source that S9088 and S9083 (global fee for urgent care centers) had been approved by the Centers for Medicare and Medicaid Services (CMS) for billing these services. What is the current status of these codes as they relate to Medicare?

– Ned Peple
A.All Healthcare Common Procedure Coding System (HCPCS) codes are created by CMS. Part of the Health Insurance Portability and Accountability Act (HIPPA) was to require CMS to develop a standard set of codes for all payors. Thus, in order to keep a standard set of codes for all payors, CMS began making HCPCS codes specifically at the request of non-Medicare payors (i.e., commercial carriers).

These codes are never for use by Medicare (even though they are created by CMS), and they all begin with the letter S. The resulting S codes are not “approved” for use by Medicare, but they were created by CMS. Thus, no S codes are billable to Medicare. Individual Medicaid payors can decide to accept S codes, but Medicaid rarely accepts S codes.

Q.How do you suggest coding for a patient who presents to urgent care in a supraventricular tachycardia (EKG performed—SVT), then converted to a normal sinus rhythm with carotid sinus massage?

– Robert Laney
A.If you use external electrical shock to the heart, then you would use 92960 (cardioversion, elective, electrical conversion of arrhythmia; external). If you perform intravenous medication (e.g., adenosine) for cardioversion, then you would use 90784 (therapeutic, prophylactic, or diagnostic injection (specify material injected); intravenous). You would add the appropriate HCPCS code(s) for the medication(s) injected. When billing for adenosine, use HCPCS code J0150 (injection, adenosine, 6 mg) to specify the injected medication.
For cardioversion via other methods, such as valsalva, carotid massage, etc., there is no specific CPT or HCPCS code. You would include this procedure as part of the evaluation and management (E/M) code.

Q.Must a physician be present in order to bill a 99211?
– Name withheld
A.A physician need not always be present to code services with 99211. The code allows practices to report E/M services that are rendered by non-provider staff members. According to CPT (as published by the AMA), the guidelines for coding a 99211 are much less strictly defined. The staff member may communicate with the physician, but the physician’s direct involvement in the episode of care is not required.

Medicare, however, interprets the requirements for this code differently. While the physician’s face-to-face presence is not required to code a service with 99211, the physician must have initiated the service as part of a continuing plan of care in which he or she will be an ongoing participant (i.e., following “incident-to” guidelines). In addition, the physician must be physically present in the office suite when the service is provided.

Thus, for services billed to Medicare, the physician must be physically on site.
For services billed to other third-party payors, your practice may instead opt to follow CPT guidelines, as long as this is allowed by your contract with the payor. If a provider is in the office, list the rendering provider as the provider who was in the office suite at the time services were rendered.

S9088 Coding for Medicare or Medicaid, Coding for SVT, and Coding 99211

David Stern, MD

Chief Executive Officer at Experity, Previous Chief Executive Offer at Practice Velocity Urgent Care Solutions, Founding Member of the Urgent Care Association of America, Publishing Staff for The Journal of Urgent Care Medicine