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CAPC Palliative Care Discussion Forum
Billing and Finance

In Reply To: Billing for family meetings + prolonged services
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Post Re:Billing for family meetings + prolonged services
Author: JulieP [Expert]
Date: Mar 20, 2009 1:16 pm

In my opinion PC providers billing critical care to patients in the ICU is not appopriate. If the patient's status in the ICU is critical, the attending provider in the ICU is the one that is directly managing the illness or injury that has placed the patient in a crtical situation. I see the PC provider assisting the family and patient in dealing with the situation at hand and what can be done in the future. I see the ICU provider managing the critical medical issues and the PC providers supporting the patient and family with the decisions that have to be made. I don't mean to underestimate the PC providers role in any way. I just don't see how you can justify billing critical care for a PC provider except in rare circumstances.
Julie Pipke CPC, Reimbursement Mngr. MCW

Replies: order by [Date] [Author] [Subject]
+ Re:Re:Billing for family meetings + prolonged services (by LorenFriedman on 03/20/2009)
julie,

i'm not sure you understand what we are doing in the ICU. As pall care physicians, we are often the docs that do a complete review of all the critical care data, discuss data with staff and docs, then have the difficult discussions with patient and family. We need to practice critical care to do this. When we write orders for WD of vent support, we are often titrating meds that are only used in critical care. Even if we are not writing orders; however, Medicare considers our assessment of patients receiving critical care as critical care. Please read the guidelines.

Medicare guidlelines allow multiple MDs to bill using the critical care codes on the same day. so a pulmonologist, a primary care doc, cardiol, nephrol, onc, GI can all bill for critical care on the same day. they just cannot bill for the exact same time slot.

if you read the 99291 guidelines, i believe that palliative med docs do critical care. i strongly believe that we should be able to get reimbursed for our services. I'm sure that your docs do more than just hold hands. It is astonishing to me how poorly many intensivists do opioid and sedative titration. Medicare considers the use of IV opioids (and discussion of EOL care) a high-level of complexity. why is an intesivist's knowledge of adjusting levophed for a pt on a vent more significant than my knowledge of IV fentanyl and IV midazolam? My comfort care may be helping to maintain organ function as much as the vasopressors.

I will stop billing 99291 if someone explains that is inappropriate. I want to do the right thing. I also want to support our program. Has anyone heard anything from Medicare about pall med and 99291?

thanks,
Loren Friedman, MD
Medical Director, Palliative Care Service
Virginia Hospital Center

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