Update on coding of facility emergency department and clinic levels of service

Since the implementation of OPPS, hospitals have coded clinic and emergency department (ED) visits using the same CPT code as physicians. CMS has recognized that existing Evaluation and Management (E/M) codes correspond to different levels of physician effort but do not adequately describe non-physician resources. Although hospitals were anticipating that CMS would propose a national, uniform E/M coding system in 2003, the agency chose not to do so. As a result, in 2003 the AHA and the American Health Information Management Association convened an independent panel of experts to develop a set of coding guidelines for CMS. In the...

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Note:  The following article synopsis was NOT provided by the AHA. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews the development and CMS review of proposed national guidance for hospital facility emergency department and clinic level-of-service reporting under OPPS. It is intended for hospital coders, revenue cycle staff, HIM professionals, and compliance teams tracking how facility E/M reporting may change, what organizations are involved, and when CMS planned to make guidance available for comment and implementation planning.

Why This Topic Matters

Hospitals need to follow evolving facility E/M reporting expectations that affect consistency, data quality, and preparation for future coding changes. This update helps readers understand the status of national guidance, the organizations shaping it, and the advance notice CMS said it would provide before implementation.

Article Sections

  1. Background on facility E/M reporting under OPPS

    Introduces how hospitals have reported clinic and emergency department visits under OPPS and why existing E/M coding did not fully address facility resource differences.

  2. Development of national coding guidance

    Describes the creation of an independent expert panel and CMS consideration of proposed national guidelines for facility-level reporting.

  3. CMS and AHA comments on proposed guidance

    Summarizes statements from CMS and the AHA regarding public comment, uniformity, and the need for consistent facility reporting practices.

  4. Final rule status and implementation notice

    Explains the status of the proposed guidance in the CY 2005 final rule and CMS communication plans for public notification and advance implementation timing.

What You Will Learn

  • How facility emergency department and clinic E/M reporting fit into the OPPS environment
  • Which organizations were involved in developing and reviewing proposed national guidance
  • How CMS planned to handle public comment and stakeholder notification
  • What advance notice CMS said it would provide before implementation

Who Should Read This

  • Hospital coders
  • HIM professionals
  • Revenue cycle teams
  • Compliance staff
  • Facility billing managers

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