The Latest in Critical Care, 3/11/24 (Issue #33)
The Latest in Critical Care, 3/11/24 (Issue #33)
Palliative care automatic consults tested. Societies fight critical care billing changes
But first:
A German “vaccine hoarder” got injected with 217 Covid vaccines, and is reportedly doing great.
Societies push back on CMS’s cuts to critical care billing
In 2022, the U.S. Centers for Medicare and Medicaid Services (CMS) made a change in reimbursement policy that devalued critical care time. (BORING CODING EXPLANATION AHEAD) Instead of the longstanding arrangement of allowing additional 30 minutes time (code 99292) to be billed after the first 30-74 minutes (code 99291), CMS instead has been effectively taking 30 minutes free, by requiring 104 minutes (1 hour 44 minutes) of critical care time to be billed under 99291 before 99292 could be added. You probably don’t ever see this–you bill as usual, but CMS reportedly doesn’t pay your hospital for any of your 99292s until billed time goes over 104 minutes.
(How your employer considers the billed-but-unpaid 99292s in your RVUs is a separate question.)
About 544,000 99292 codes were billed to CMS in 2021, according to ACCP, reportedly stable at about 10% of the total bills. At about $100 per, they would be worth ~$54 million in total. Let’s say clinicians billed >104 minutes on ⅓ of those (which CMS would then pay for), and 75-103 minutes on the other ⅔ (which CMS would not). That’s a savings to CMS of $36 million per year–or ~0.0024% of total CMS outlays of $1.5 trillion in 2023.
Is that enough savings to justify sticking it to the hardest working docs in medicine? ACCP, SCCM, ATS, ACEP and ASA don’t think so. Read their letter to CMS here, asking that critical care billing return to pre-2022 historical norms.
In 2022, CMS also officially permitted concurrent or additive critical care time billing by multiple clinicians on the same patient throughout the day. Although CMS haven’t said so, the change in 99292 billing could have been enacted to soften any increased billing from that change.
Our Pal Care service has deliberately avoided automatic consults because the added volume makes it very difficult to focus their resources on appropriate consults. I think most pal care physicians anecdotally know these findings, and you will see that when they push back against the reconsult for the end-stage something patient who just isn’t “realistic.”