Comprehensive Error Rate Testing (CERT) Focus on CPT 99211
Annually, the Centers for Medicare and Medicaid Services monitor the accuracy of Fee-For-Service (FFS) payments. CMS contractors use the Comprehensive Error Rate Testing (CERT) program to determine which services are experiencing high error rates. One particular topic recently highlighted was the incorrect use of evaluation and management code 99211.Per the 2009 Current Procedural Terminology (CPT) manual, 99211 is “Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services.” Below are examples of the CERT reviewer comments where insufficient documentation resulted in refunds from the providers: * Documentation reviewed includes no supporting documentation or presenting problem/symptom or medical evaluation provided. Documentation supports prothrombin anticoagulation check (CPT 85610) which is found billed separately for same date of service. * Note from provider states, “Patient had labs done only. Did not see the doctor.”
Documentation consists of protime results and instructions on drug dosage. * Flow sheet received contains only the “results of the test, continue same, and check in 2 weeks.” There is insufficient documentation to indicate that there was any E/M service performed. It would appear that the encounter was exclusively for the purpose of venipuncture. * There is no documentation of a face to face, separately identifiable E/M service to support billed CPT 99211. There are no circumstances documented to demonstrate a need for clinical evaluation and management. Submitted is an “Anticoagulant Flow Sheet” with date, INR results, current dose, new dose, ordered by, notified by, next check, and comments. * Submitted are physician records stating “Here for his first Synovisc injection.” Arthrocentesis and synovisc injection codes also billed this claim for same date of service. Noted use of modifier 25 (significant, separately identifiable evaluation and management service by the same physician on the same day of the procedure or other service), however, submitted documentation does not support modifier code; documentation states “detailed note is in the chart from his last visit.”As with all E&M codes, 99211 requires a face to face encounter consisting of elements of evaluation and management.
When the record contains documentation of a clinically relevant exchange of information, the evaluation is substantiated. The management portion is substantiated when the record demonstrates an influence on patient care (ex.; medical decision making, patient education, etc.). CPT 99211 should not be used for: -Phone calls to patients -Drawing of blood for laboratory analysis or when performing other diagnostic tests -Administration of medications when an injection or infusion code is submitted separately -Non-physician providers may perform 99211 services if their state licensing permits the conduct of patient care. These can be billed to Medicare as incident-to services when there is a physician service to which the non-physician providers’ services relate. From www.medical-coding.net, a division of Provistas (www.provistas.com), home of SpeedECoder software (www.speedecoder.com).


