One aspect of at-home testing and monitoring not often spoken about is its effect on evaluation and management office codes when the patient either presents to the office or if you are using a 992XX code for a telemedicine-based encounter. However, there are some caveats and rules that we must consider when applying this paradigm—especially when the testing is done by an Independent Diagnostic Testing Facility (IDTF).
Determining your evaluation and management (E/M) code level, whether with a new or established patient, uses the current definition of total time or medical decision-making (MDM). Total time consists of nine elements:
- Preparing to see the patient.
- Taking additional or reviewing previously taken history.
- Performing your medically appropriate exam.
- Counseling/educating patient, family, caregiver.
- Ordering medication, tests or procedures.
- Referring and communicating with other health care providers.
- Documenting the medical record.
- Independently interpreting test results and communicating them.
- Coordination of care.
When using MDM, keep in mind the three categories to score its level:
- Number and complexity of problems addressed.
- Amount and/or complexity of data to be reviewed and analyzed.
- Risk of complications and/or morbidity.
Let’s use a common remote test, the ForeseeHome by Notal Vision, as an example of an at-home monitoring technology used for age-related macular degeneration. Notal has established a Category III code for its test and has established itself as an IDTF.
An IDTF only accepts patients referred by an attending physician who is providing a consultation or treating a beneficiary for a specific medical problem and who uses the results in the management of the patient’s specific medical problem. The IDTF bills for and gets paid for its testing directly from the carrier—an important distinction.
The Category III code that Notal uses as an IDTF is:
• 0379T: Visual field assessment, with concurrent real time data analysis and accessible data storage with patient-initiated data transmitted to a remote surveillance center for up to 30 days; technical support and patient instructions, surveillance, analysis and transmission of daily and emergent data reports as prescribed by a physician or other qualified health care professional.
Understand that the physician/IDTF roles are pivotal in being able to use the information in coding for your E/M visits. The physician orders the tests but is not responsible for administering it, nor getting paid to interpret it. That is the role of the IDTF. Whether we are using time or MDM to score our encounter, it is vital that we are not getting reimbursed in any way for the remote monitoring activity.
Review the Data
When using time to score the E/M visit, the physician can measure the component of “independently interpreting test results and communicating them” to the patient or responsible caregiver. This information can also be entered into the medical record and that can add additional time. If using MDM, this would impact our second category of “amount and/or complexity of data to be reviewed and analyzed” under the bullet point of “review of the results of each unique test.”
Reviewing data from a test that we have not been paid for by other means is an important differentiator here. For example, if a visual field had been ordered and performed by the practitioner, the interpretation of that test would already be included in the reimbursement of that specific test and could not be used to add to the E/M visit.
Technology will continue to advance, and patient convenience is going to be a critical driver along with the clinical merits. Understanding your role in independently interpreting test results that are done by an IDTF or other practitioners not only plays a significant part in patient management but also contributes to the amount of time spent or the amount and complexity of data required, thus impacting the coding of your E/M office visit.
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Dr. Rumpakis is president and CEO of Practice Resource Management, Inc., a firm that provides consulting, appraisal and management services for health care professionals and industry partners. As a full-time consultant, he has provided services to a wide array of ophthalmic clients. Dr. Rumpakis’s full disclosure list can be found here.