I know that a Podiatrist can use CPT codes 99222 & 99223. However, I have been told and heard multiple times the scope of practice typically prevents reaching the guidelines for these codes. Is this true? If not, in what circumstances (examples) would meet the requirements?
Thank you for any additional guidance / education!
CPT codes 99221-99223 can be billed if the physician is listed as the admitting physician of record. If not, the admitting physician you would bill with 99231-99233.
As far as their scope of practice, DPMs are trained and fully licensed to independently perform all aspects of history and physical (H&P) examinations in any setting for any patient, this includes, level of history, exam and medical decision making. However, each State has its own rules for podiatric scope of practice, I would recommend contacting the state the Podiatrist is practicing in for additional information.
Medicare allows CPT 99221-99223 to be reported by a non-admitting provider for an initial visit for a specialty consultation during an admission. This has been allowed since they stopped covering consultation codes.
I do not have any examples, but in my opinion it can be a slippery slope when you provide examples on how to meet a higher code level. Each encounter is case by case, and we don't want to make the mistake of leading our providers to documenting more just to meet a higher code level. Shadowing a provider during their rounds or inpatient visits may help you to identify any missed elements/work performed that has not been included in their documentation, thereby allowing you to see if the efforts support a comprehensive history and exam levels required, along with the moderate or high complexity MDM.
Since many of us who audit and code may not have clinical backgrounds, we can point out what may appear to be note bloat in order to reach a code, and of course mention the well known, "Medical Necessity is the overarching criterion for payment", but the medical need to perform certain levels of history, exam and MDM is ultimately the provider's decision.
If the DPM can reach the correct components of each exam he can bill an E/M code, I don’t see why there would be a problem. Unless the Podiatrist does not do the following elements, their license does not exclude any of the following. This information is from the Evaluation & Management guidelines.
The descriptors for the levels of E/M services recognize seven components which are used in defining the levels of E/M services.
These components are:
• medical decision making
• coordination of Care
• nature of presenting problem
The first three of these components (i.e., history, examination, and medical decision making) are the key components in selecting the level of E/M services. An exception to this rule is the case of visits which consist predominantly of counseling or coordination of care; for these services, time is the key or controlling factor to qualify for a level of E/M service. For certain groups of patients, the recorded information may vary slightly from that described here. Specifically, the medical records of infants, children, adolescents, and pregnant women may have additional or modified information recorded in each history and examination area.