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Reimbursement for Palliative Care in the ICU By Intensivists
To an intensivist, providing palliative care often means having multiple time-consuming and emotionally challenging interactions with families struggling to cope with the impending loss of their loved one. The emotional content of these interactions can be strongly positive, negative, or somewhere in between, but frequently it's an intense and draining experience, possibly contributing to burnout among ICU physicians.
So at least you should get paid for it, right?
Dana Lustbader et al explain how to do so while complying with the regulations of the Centers for Medicare and Medicaid (CMS) in the April 2012 Chest:
- Current Procedural Terminology (CPT) time-based codes 99291 (for critical care services from 30 - 74 minutes) and 99292 (for each additional 30 minutes over 74 minutes) can legally and ethically be used to bill payers for palliative care services by intensivists.
- Examples that authors say meet the standard include family meetings discussing goals of care, end-of-life care, tracheostomy placement or other procedures, and managing distressing symptoms in a patient under comfort care.
- Needless to say, everything must be documented well to support the billing.
- 99291 (30-74 min.) pays about $243 and is valued at 4.5 revenue value units (RVUs).
- 99292 pays about $122 for each additional 30 minutes spent.
- (If total time is <30 minutes, it's to be reported under a different set of E/M codes 99231-99233. The highest-paying in this set, a level 3 visit under 99233, pays $105 and is only 1.0 RVU.)
- Time spent after returning to a patient's bedside late in the day for a family meeting to establish goals of care can be added to the time spent earlier that morning providing direct medical care.
- All the initial time under 99291 (30-74 min.) must be performed by the billing MD (i.e., not a midlevel).
- Any physician, not just a palliative care physician or critical care-boarded physician, may bill for palliative care using these time codes.
Caveats and Pitfalls to Billing for Palliative Care in the ICU
"Split or shared service performed by a physician and a qualified nonphysician provider of the same group practice is not reportable as a critical care service; only cumulative critical care time provided by physicians within a group is reported as such." In other words, midlevels cannot bill for palliative care services (i.e., a PA can't have a 30 minute meeting and you bill it under the "+30 min" 99292 code).
The above goes for residents' work, as well, at teaching hospitals, where attendings must also document care well enough for it to justify billings independent of the resident's note.
Critical care services must be medically necessary (just being in the ICU is not sufficient). CMS's definition of this for critical care services is: “The treatment and management of the patient’s condition, while not necessarily emergent, shall be required, based on the threat of imminent deterioration.”
Counseling, bereavement, and general emotional support are not billable under the critical care codes 99291 and 99292. Apparently, Medicare decided just being nice should be on the house.
Lustbader DR et al. Physician Reimbursement for Critical Care Services Integrating Palliative Care for Patients Who Are Critically Ill. Chest 2012;141:787-792.