Facility Transfers

The Hospitalist. 2009 September;2009(09):

September 1, 2009 | The Hospitalist

Additionally, a consultation service (99251-99255) should not be reported, because the request involves the completion of a facility-mandated form and not an opinion or advice on caring for the patient. If medical issues require the hospitalist’s evaluation and management, there is medical necessity for capturing the hospitalist’s participation as subsequent hospital care (99231-99233). If no medical conditions present for the hospitalist to manage, the service will not be considered “medically necessary” by the payor.

Interfacility

Hospitalist groups provide patient care and coverage in a variety of facilities. Confusion often arises when the attending of record during acute care and the sub-acute setting are different hospitalists from the same HM group. The hospitalist who receives the patient in the transfer facility may err on the side of caution and report subsequent hospital care (99231-99233) because the group has provided ongoing patient care. In this scenario, the hospitalist group might lose revenue if an admission service (99221-99223) was not reported.

Day of Transfer Billing

A single hospitalist or two hospitalists from the same group might bill both the hospital discharge management code (99238-99239) and an initial hospital care code (99221-99223) when the discharge and admission do not occur on the same day if the transfer is between:

Different hospitals;
Different facilities under common ownership that do not have merged records;* or
Between the acute-care hospital and a prospective payment system (PPS)-exempt unit within the same hospital when there are no merged records.

In all other transfer circumstances that do not meet the elements noted above, the physician should bill only the appropriate level of subsequent hospital care (99231-99233) for the date of transfer.1 Of note, Medicare Part A covers inpatient care in psychiatric, rehabilitation, critical access, and long-term-care hospitals. Each of these specialty hospitals is exempt from the PPS established for acute-care hospitals in 1983.2 TH

Carol Pohlig is a billing and coding expert with the University of Pennsylvania Medical Center in Philadelphia. She is faculty of SHM’s inpatient coding course.

*Editor’s note: “Merged record” is not equivalent to commonly accessible charts via an electronic health record system. If the medical record for the patient’s acute stay is “closed” and the patient is given a separate medical record and registration for the stay in the transferred facility, consider the transfer stay as a separate admission.

References

Centers for Medicare and Medicaid Services. Medicare Claims Processing Manual: Chapter 12, Section 30.6.9.1E. CMS Web site. Available at: www.cms.hhs.gov/manuals/downloads/clm104c12.pdf. Accessed June 1, 2009.
Department of Health and Human Services. Office of Inspector General: Oversight of Medicare PPS-Exempt Hospital Services. HHS Web site. Available at: www.oig.hhs.gov/oei/reports/oei-12-02-00170.pdf. Accessed June 1, 2009.
CMS. Medicare Claims Processing Manual: Chapter 12, Section 30.6.9.1H. CMS Web site. Available at: www.cms.hhs.gov/manuals/downloads/clm104c12.pdf. Accessed June 1, 2009.

Consultation Reminder

Pay attention to the consultation requirements before you assume a physician’s involvement in patient care constitutes a consultative service. The intent of a consultation service is limited to a physician, qualified non-physician practitioner (NPP), or other appropriate source asking another physician or qualified NPP for advice, an opinion, recommendations, suggestions, directions, or counsel, etc., in evaluating or treating a patient because that individual has expertise in a specific medical area beyond the requesting professional’s knowledge.3 In order to report a service as a consultation, identify and document these factors:

A consultation request from an appropriate source shall be documented by the consultant in the patient’s medical record and included in the requesting physician or qualified NPP plan of care in the patient’s medical record;
The reason for consultation shall be documented by the consultant in the patient’s medical record and included in the requesting physician or qualified NPP plan of care in the patient’s medical record;
After the consultation, the consultant shall prepare a written report of findings and recommendations, which shall be provided to the referring physician. A separate, dictated letter or other form of written communication does not need to be sent to the requesting physician when the requesting physician and consultant share a common medical record. The progress note in the inpatient medical record serves as the consultant’s communication to the requesting physician.