Coding Questions on TCM Services, Code 99358

July 28, 2017
Bill Dacey

Coding expert Bill Dacey answers your latest coding questions, including an inquiry on how to bill for TCM services.

Q: Can we bill for Transitional Care Management services (TCM) Current Procedural Terminology (CPT) Code 99495 if a patient went in for colonoscopy, had a seizure, and was admitted for observation and work up? Or is that included in post op global period?

A: Per the CPT manual, you can use a TCM code for follow up related to an observation stay, just like you would for an inpatient stay. That is of course if you meet the requirements of the code, the 2-day contact, the timing of your visit, and the documented moderate level decision-making for the 99495. The global period only applies to the provider doing the scope. If your provider (or no member of your group of the same specialty) did not do the scope, then no global applies here.

Q:  I have a few questions on how to bill the newly payable 99358 code. Let's say our providers review the records after the patient visit, how do I post the charges for this? What diagnosis will we bill with this? Are we having the docs addend the previous office note (to document time spent)? Is it ok for them to document in a clinical message that they reviewed the records, spent x amount of time and to bill the 99358 code?

A: Lot of questions in here! As to posting charges, I don't know how a provider 'creates' an encounter in your system, but that is basically what you need to do.

Remember, the important part to this 'non-face-to face' prolonged service visit is that it is a distinct service from an E&M. It was not likely intended to be done on the same day as an E&M visit. The decision-making component of an E&M visit can include review of old records, but is excluded from the typical E&M codes by the national correct coding initiative (CCI).

So what we are looking for is a clearly separate minimum of 30 minutes spent in record review or some other medically necessary activity that is documented in a note. You could addend an old note, but we need to see clearly the date of service of the new work you did. It needs to be a distinct service as above and a separate entry goes away towards that end.

To that point, I don't think you want a 'clinical message' either - all these suggestions have the effect of diminishing the service rather than presenting it as a discrete and billable service. In addition to the documentation that the doctor spent at least 30 minutes performing the service, to bolster this do a brief summary of the records reviewed, or the research conducted.

Q:  It is our understanding that CMS is requiring that special reporting be done for all post op visits starting in July 2017. Is this true? Where is the specific guidance on this?

A: You are partially correct. There is a CMS initiative to require special reporting of post-op visits for certain CPT codes with 10 and 90-day global surgical periods.

This does not apply to all surgeries, however. There is a list of 293 codes which will require that the providers performing these services on or after July 1, 2017 will need to report CPT code 99024 for every post-op encounter related to these services. This includes inpatient and outpatient encounters, and pertains only to the provider (or member of the provider group) that billed the global procedural code.

To obtain the list, click here.