September 20, 2007
Billing 99211 for Anticoagulation Management
CPT code 99211 is the lowest level evaluation and management (E/M) service and does not require a physician face-to-face encounter with the patient. However, it does require direct physician supervision (i.e. the supervising physician must be present in the office when the service is rendered) of the ancillary staff who are conducting the face-to-face encounter. Services billed to Medicare under CPT code 99211 must be reasonable and necessary for the diagnosis and treatment of an illness or injury. This would include appropriately performed and documented anticoagulation management.
The following represents the guidelines that would be used in review of these charges as well as the errors that have previously been found on carrier or Comprehensive Error Rate Testing reviews.
99211 for Anticoagulation Management “Do’s”
- Documenting the patient’s indication for anticoagulant therapy, current dose, protime and INR results
- Assessing the patient in-person for signs and symptoms of bleeding/adverse effects to anticoagulant therapy
- Assessing the patient for changes in health status that may impact or account for fluctuations in lab results (for example, new or changed medications that may cause a drug interaction with the anticoagulant therapy)
- Providing medically necessary education as needed based on the patient’s individual circumstances
- Documenting the identity of the ancillary staff performing this service “incident to” the supervising physician
- Documenting the identity of the billing physician who was notified of results, gave orders, and provided direct supervision
99211 for Anticoagulation Management “Don’ts”
- Billing for 99211 when the in-person encounter with the patient was only for the diagnostic test
- Billing for 99211 for telephone care, i.e. instructions on changing dose, assessment, and/or education
- Billing for 99211 when the only documentation would be vital signs, the patient’s current and future dose of anticoagulant, and when lab work is to be repeated
- Billing for 99211 when direct physician supervision is not met or is not by the physician treating the patient’s medical problem requiring anticoagulant therapy (i.e. as seen in some “Coumadin ® clinic” scenarios)
- Billing for 99211 based on the delivery of repetitive education that does not serve the medical needs of the individual patient
Additionally (and not just limited to anticoagulation management), 99211 should not be used for:
- routine, in-person prescription renewals unless the patient’s condition requires reevaluation prior to the renewal determination
- routine blood pressure checks that have no impact on patient’s care
- performing diagnostic or therapeutic procedures
