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Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

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Page 1: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Eric Goplerud, Ph.D.The George Washington University Medical Center

Screening, Brief Intervention, Treatment and Recover Support:Getting Paid

Page 2: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

2

Why won’t health care providers conduct routine screenings, brief counseling and treatment for substance use problems?

Page 3: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems3

Obstacles to SBIRT

No time.

What’s the point?

Don’t know how.

Can’t afford it.

Page 4: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems4

Page 5: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems5

What Does SBIRT Cost?

It depends on how you do it. Screening

Bioassay Online Paper and pencil as HRA or in a health-related location or

event Automated telephone service PDA linked to electronic medical record Pop-up on electronic medical record Interview

Page 6: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems6

What Does SBIrt Cost?

It depends on how you do it. Brief Intervention and Brief Treatment

Length of time Type of provider Setting Follow-up method

Specialty treatment

Page 7: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems7

SBIRT Cost Estimate

Screening

• Low cost = $2.50 per screen

No lab, 5 minute screening by health educator

• High cost = $38.00 per screen

Lab plus 10 minute screening by mid-level professional

http://gunston.doit.gmu.edu/healthscience/730/SBIRT/

Page 8: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems8

SBI Cost Estimate

Brief Intervention

• Low cost = $10.00 per intervention

10 minute intervention by health educator plus follow-up call

• High cost = $112.50 per intervention

30 minute intervention by mid-level professional plus follow-up visit or call

http://gunston.doit.gmu.edu/healthscience/730/SBIRT/

Page 9: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems9

Conditions Affecting Hit Rate

Screening factors Setting & patient population Instrument used and threshold for positive

results

Brief Intervention & Treatment Factors Setting & patient population Type of model Whether routine, targeted or opportunistic

Page 10: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems 10

Likelihood of Positive Screen, BI and Treatment

0%

10%

20%

30%

40%

50%

PositiveScreens

BI Needed TX Needed

Ambulatory Medical Inpatient MedicalHospital Emergency Dept. Trauma CenterMental Health Ambulatory Inpatient Psychiatric

Page 11: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

5%Harmful

Use

21% (26.25 million)

At RiskExceed daily

limits.

70%(87.5 million)

No ProblemNever exceed daily limits.

Willenbring, 2007

Spectrum of Alcohol Problems

5%(6.25 million)

Harmful Use

Exceed daily limits.

Related problems.

3%(3.75 million)

Dependence

Daily or near-daily heavy drinking.

Related problems.

Withdrawal

1%(1.25 million)

Chronic Dependence

Almost-daily drinking.

Related problems.

Withdrawal

Chronic or relapsing.

Page 12: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

High Risk and Hazardous Alcohol Use

Targeting the 21% who drink in ways that place themselves at risk for health problems and injury

Center for Integrated Behavioral Health Policy

Page 13: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems13

Getting Paid for SBIRT

HCPCS New codes approved by CMS

H0049 Screening H0050 Brief Intervention

In effect as of January 1, 2007 No state Medicaid agencies currently pay on these codes

Close in some states – AZ, AK, WA

Page 14: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems14

What did we learn?

Without CMS leadership

Page 15: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems15

Getting Paid for SBIRT: The Big Deal

Page 16: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems16

New codes approved by AMA Active since January 2009 99408

Alcohol and/or substance use structured screening (eg, AUDIT, DAST), and brief intervention (SBI) services; 15 to 30 minutes

99409    greater than 30 minutes

Diagnosis will be dependent on payer (V82.9)

CPT – Common Procedure Terminology

Page 17: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems17

Payment

CMS Schedule Published in November 2008 RUC recommended values

99408 ~$24 99409 ~$48

Can be billed as a separate or added service CPT codes adopted by most health plans (86% commercial insurers) and 17 State Medicaid Aetna, CIGNA, Anthem Blue Cross and Blue Shield, HealthPlus,

HealthPartners, Office of Personnel Management (Federal Employees)

Page 18: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

18

Reimburses, or will reimburse on SBI Codes 99408/99409

Aetna California PPO 310

Anthem California National PPO 152

BC of California HMO 0

Health Net of California HMO 0

Health Net of California PPO 26

Kaiser Northern California HMO 58,739

Kaiser Southern California HMO 48,000

UnitedHealthcare of California PPO 5

Page 19: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Reimbursement for SBIRT

• Resource Based Relative Value Scale (RBRVS)– Relative Value Units (RVU)

• Used by Medicare and HMO’s to establish rates

• Medicaid has fee schedule amounts based on rendering provider

Page 20: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

What gets paid, gets done.99203 Office/outpatient visit, new, 30 minutes 2.54

99283 Emergency dept visit, moderate complexity 1.68

99443

98968

Physician or healthcare prof. follow-up phone call 21-30 min (Not Medicare reimb.)

0.98

99420 Administration, interpretation of health risk assessment instrument (not Medicare reimb.)

0.23

99402 Preventive medicine, individual, 30 min (not Medicare reimb.)

1.48

38100 Removal of spleen, total 28.23

61514 Removal of brain abscess 48.04

99409 SBI 30 minutes or more 1.67

RVUs

Page 21: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

2008 RVUs for SBI and comparable clinical procedures RVUs

90804 Psychotherapy, office, 20-30 min 1.80

90816 Psychotherapy, hospital, 20-30 min 1.60

99202 Office/outpatient visit, new 20 min 1.77

99408 SBI 15 to 30 min 0.85

99203 Office/outpatient visit, new 30 min 2.54

99385 Prevention visit, new, age 18-39 2.66

99409 SBI over 30 min 1.67

Page 22: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Reimbursement for SBIReimbursement for SBIPayer Code Description Fee Schedule

Commercial Insurance and

Medicaid

CPT 99408

Alcohol and/or substance abuse structured screening and brief intervention services; 15 to 30 minutes

$33.41

CPT 99409

Alcohol and/or substance abuse structured screening and brief intervention services; greater than 30 minutes

$65.51

Medicare

G0396

Alcohol and/or substance abuse structured screening and brief intervention services; 15 to 30 minutes

$29.42

G0397

Alcohol and/or substance abuse structured screening and brief intervention services; greater than 30 minutes

$57.69

Page 23: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Explanation from the AMA“A screening & brief intervention (SBI) describes a different type of patient-physician interaction. It requires a significant amount of time and additional acquired skills to deliver beyond that required for provision of general advice. SBI techniques are discrete, clearly distinguishable clinical procedures that are effective in identifying problematic alcohol or substance use.”

AMA CPT Symposium, November 2007

Page 24: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Explanation from the AMA• Recognizes the importance of screening

and intervening for the person who is not necessarily an identified substance abuser (e.g. in the ED for a trauma)

• The screening uses structured validated assessments, although there is no maintained list

• The screening and intervention must be a minimum of 15 minutes in duration

AMA CPT Symposium, November 2007

Page 25: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Explanation from the AMA• Components include:

– Use of a standardized screening questionnaire.– Feedback concerning screening results.– Discussion of negative consequences that have

occurred; and the overall severity of the problem.

– Motivating the patient toward behavioral change.– Joint decision-making process regarding alcohol

and/or drug use.– Plans for follow up are discussed and agree to.

AMA CPT Symposium, November 2007

Page 26: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Clinical Definitions and Billing

• Brief screening is not a separately billable service– Full Screen or Brief Assessments are billable

• Intervention can include:– Brief intervention– Brief treatment– Referral– Follow-up

Page 27: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Medicare’s Equivalent

• Medicare codes for SBI– G0396

• Alcohol and/or substance abuse (other than tobacco) abuse structured assessment (e.g. AUDIT, DAST) and brief intervention, 15 to 30 minutes

– G0397• Greater than 30 minutes

Page 28: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Why are the Medicare Codes Different?

• CPT codes suggest the potential to include “screening services”.

• Medicare does not typically cover screening services in the absence of signs/symptoms or illness/injury.– Would not meet the statutory requirements for

coverage of a screening service outlined in §1862(a)(1)(A) of the Social Security Act.

Source: CMS Transmittal 1423

Page 29: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Why are the Medicare Codes Different?

• Medicare caveat– “when performed in the context of the

diagnosis or treatment of illness or injury.”– Medicare will make payment to physicians

only when appropriate and reasonably necessary (i.e., when the service is provided to evaluate patients with signs/symptoms of illness or injury)

• Diagnosis should not be a screening diagnosis

Source: CMS Transmittal 1423

Page 30: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Time-Based Codes

• Both the CPT & Medicare codes are time-based– Carefully document the time spent in

counseling and interviewing to support the code billed

– If billing an office visit (Evaluation and Management) E&M service, the SBI must be separate and identifiable.

Page 31: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Documentation for Coding Based on Time

“In the case where counseling and/or coordination of care dominates (more than 50%) of the physician/patient and/or family encounter (face-to-face time in the office or other or outpatient setting, floor/unit time in the hospital or nursing facility), time is considered thekey or controlling factor to qualify for a particular level of E/M services.”

DG: If the physician elects to report the level of service based on counseling and/or coordination of care, the total length of time of the encounter (face-to-face or floor time, as appropriate) should be documented and therecord should describe the counseling and/or activities to coordinate care

Source: CMS 1997 E&M Documentation Guidelines

Page 32: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

What about Health Educators?

• Health educators are considered ancillary/auxiliary providers– Not credentialed with private or federal payers– Typically able to operate under supervision of

a credentialed provider (MD, DO, PA, NP)• Direct Supervision• Adhere to plan of care• Co-signature requirement on documentation

– Codes reported will depend on payer

Page 33: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Health Educator is the Provider• Medicaid

– Billing under E/M codes as ancillary provider type using CPT 99211 or 99212

• Medicare– Bill “Incident-to” using CPT 99211

• Commercial Payers– SBIRT codes “under supervision”

• Is it mental health benefit or medical benefit?

Page 34: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ancillary Provider Guidelines• Medicaid rules include:

– Direct, immediate, on-site supervision of a physician

– Services are pursuant to the plan of care– The supervising physician has not also

provided Medicaid reimbursable service during the same office or outpatient E&M

• Can’t bill in addition to or combine the services

• Health educators meet the definition of ancillary provider

Page 35: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ancillary Provider Guidelines

• Claims are submitted to Medicaid using the supervising physician’s NPI – Using the lowest appropriate level office visit

CPT code for the services performed, typically a 99211 or 99212

– Supervising physician is rendering provider

Page 36: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

99211 and 9921299211: “Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services.”

Source: CPT Professional Edition ,2009

Page 37: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

99211 and 9921299212: “Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components:

• A problem focused history• A problem focused exam• Straightforward medical decision making

Usually, the presenting problem(s) are self limited or minor. Physicians typically spend 10 minutes face to face with the patient and/or family.

Source: CPT Professional Edition ,2009

Page 38: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

The Setting Matters• Site of service for SBIRT may include:

– Ambulatory outpatient• Office, hospital outpatient

– Place of service 11, 22

– Emergency department• Place of service 23

– Hospital Inpatient• Place of service 21

– FQHC/Public Health Clinic• Place of service 50/71

Page 39: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT In the Office• Free standing office

– Place of Service 11

• Provided by the health educator– Know your payers and contracts:

• Commercial 99408 & 99409– Under supervision

• Medicare (Incident to)– Established E&M service (CPT 99211)

• Medicaid (Ancillary Service)– CPT 99211 or 99212

» (documentation requirements or time)

Page 40: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in a Provider Based Clinic or Outpatient Hospital

• Place of service 22

• Billing codes depend on payer and provider of service

• Depends on who employs the health educator or physician

Page 41: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in a Provider Based Clinic or Outpatient Hospital

• May be applicable facility code (technical) billed to in addition to professional code when provider based– Can’t bill “incident-to”, supervision requirements

are different– Revenue Code 942 on UB-04 and SBIRT Code

Page 42: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Medicare Supervision RequirementsSupervision: The policy for general supervision in the outpatient hospital setting is different from the direct supervision requirements for the office/clinic setting. Supervision requirements for outpatient hospital settings are the same as the definition at 42CFR 410.27 for services at provider based facilities. The physician/NPP supervision requirement in the outpatient hospital setting is generally assumed to be met where the services are performed on hospital premises. However, to assure the assumption is appropriate, there must be a physician/NPP, who is a member of the hospital staff, on the hospital premises at the time of the service and immediately available to render assistance and direction throughout the performance of the procedure. Documentation must indicate that this requirement is met.

Source: Medicare Benefit Policy Manual (MBPM) Chapter 15 section 60

Page 43: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

“Immediately Available” Defined

"Immediately available" in the outpatient hospital setting may be interpreted as equivalent to the availability of a physician/NPP designated to manage arrests in the hospital. The supervisor need not be in the same department as the ordering physician/NPP or in the same department in which the services are furnished. The supervisor may be identified in the medical record or hospital policy by job description, rather than by name. For example, there may be a hospital medical officer, or the physician/NPP responsible for the cardiac arrest team. As long as the supervisor will be in the hospital, immediately available if needed, and can be identified by the hospital for purposes of Medicare claim review.

Source: Social Security Act (SSA) Section 1861(s)(2)(K)(i)

Page 44: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Who Employs the Billing Provider Makes a Difference

• Could be:– Independent billing physician– Hospital employee– Employee under contract

• CPT codes for E&M services will be established or new office/outpatient codes– 99201-99205 (new)– 99211-99215 (established)

• Health educators are limited by payer

Page 45: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in the Emergency Department

• Place of service 23

• Will be a facility charge as well– If SBIRT service is provided by salaried

employee of the hospital, it is included in the facility charge and no professional service is billed

• Billing codes depend on payer and provider of service

Page 46: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in the Inpatient Setting

• Place of service 21

• Billing codes depend on payer and provider of service

• Could include patients in med/surg, ICU, psych, or other inpatient area.

Page 47: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in the FQHC

• Place of Service 50

• Same coding guidelines as freestanding clinic– Reimbursement is different

Page 48: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Smoking and Tobacco Cessation

Page 49: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

CPT Codes

• 99406: Smoking and tobacco use cessation counseling visit; intermediate, greater than 3 minutes up to 10 minutes

• 99407: intensive, greater than 10 minutes

Page 50: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Rules in General• Face to face• Time and counseling must be documented

– And subtracted from E&M time

• Can be used multiple times

Example: If the E&M visit took 25 minutes and the smoking cessation was provided face to face for 15 minutes, the E&M if based on time, would be 10 minutes. (99212)

– Modifier 25 appended to the E&M

Page 51: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Smoking Cessation ~Commercial Payer~

• Provided by health educator– Ancillary service under on-site supervision– E&M on same day by physician

• Documentation must indicate ancillary service by who, and include the counseling elements and time

Page 52: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Smoking Cessation~Medicare~

• CPT 99406 & 99407– Same CPT definitions– Deductible and co-insurance apply– Can bill E&M on the same day with modifier 25– Limited to 8 smoking cessation attempts in a

12 month period

Page 53: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Diagnosis Requirement

• Diagnosis code must reflect the condition that is adversely affected by tobacco use,

or

• The condition the patient is being treated for with a therapeutic agent whose metabolism or dosing is affected by tobacco use

Page 54: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Medicare Definitions

• Cessation counseling attempt: occurs when a qualified practitioner determines that a beneficiary meets the eligibility requirements and initiates treatment with a cessation counseling attempt.

• 1 Counseling attempt = up to 4 sessions– 2 allowed per 12 months

Page 55: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Medicare Definitions

• Cessation counseling session: Face to face patient contact of either the intermediate (3-10 minutes) or the intensive (greater than 10 minutes) type performed either by or “incident to” the services of a qualified practitioner for the purposes of counseling the beneficiary to quit smoking or tobacco use

Page 56: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Reimbursement• Commercial Average

– 99406: $13– 99407: $30

• Medicare:– 99406 Non-facility $12.46 Facility $ 11.13– 99407 Non-facility $24.16 Facility $23.16

• Medicaid– Provided as E/M as ancillary service

• 99211 or 99212

Page 57: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Billing with Evaluation and Management

(E&M) Codes

Page 58: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

58

SBI Reimbursement Strategies

Providers can be reimbursed for SBI – even without specific codes.

http://www.ensuringsolutions.org/resources/resources_show.htm?doc_id=385233&cat_id=964

Page 59: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Evaluation & Management (E&M) Elements

• History, Exam and Medical Decision Making– Need 3 of 3 for new patients (99201 – 99205)– Need 2 of 3 for established patients

(99211 -99215)

Page 60: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Evaluation & Management (E&M) Elements

• Or may report based on time– Greater than 50% of visit must be counseling

and/or coordination of care• Documentation is key!

– Both time and “what” the counseling entailed– Example: I spent 15 minutes with the patient today and

all 15 minutes were used counseling the patient on potential risk behaviors.

» The note should include the nature of the counseling

Page 61: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Billing with E/M Codes• Physicians are typically defined by

specialty and group– All physicians within the same specialty, same

group = 1 physician for billing purposes

Example: Two primary care physicians provide two E&M services on the same day to the same patient, only one E&M can be billed, combining documentation

Page 62: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Multiple Services on the Same Day

• Physicians can bill for an E&M and the provision of SBIRT services on the same day when personally performing the services– Example: 99214 (E&M, established patient) &

99408 (SBIRT for commercial payer)– Example: 99203 (E&M, new patient) & G0396

(SBIRT for Medicare)

Page 63: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Example50-year-old male seen for unscheduled visit for cold symptoms and wheezing. History of acid reflux, headaches, mild hypertension, alcoholism in three first-degree relatives. The patient recently lost his job, and uses alcohol socially several time per week.

DX: URI, prescribed an inhaled beta-2 agonist. The physician assessed risk of alcohol use disorder with a standard 10-item AUDIT questionnaire. Patient provided feedback about drinking and medical concern, generated option to reduce drinking, developed plan and commitment to change. Greater than 30 minutes of SBI.

E&M and 99409 may be billed

Page 64: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Example

Patient presents for an annual preventive exam. During the exam, physician performs a CAGE survey to assess alcohol abuse as protocol. Patient is referred to an alcohol program. Twenty minutes is spent convincing the patient there is a drinking problem.

The service described does not sound like specific SBI interventions, but may be reported with an E&M.

AMA CPT Symposium, November 2007

Page 65: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Multiple Services on the Same Day

• If a physician and a health educator provide multiple services to the same patient on the same day, only the physician (credentialed provider) may bill for services.– E&M would be billed based on the 3 elements or

on time and counseling/coordination of care– Only historical elements from the health educator

could be included in the level of service• Past family, social, medical history, and• Review of systems (For Medicare)

Page 66: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Site of Service Matters

Page 67: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in the ED

• CPT codes are:– 99281-99285– SBIRT Can be billed in addition when

performed by a credentialed provider• 99408, 99409, G0396, G0397• Would be rare for separate payment to health

educator

Page 68: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems

68

Page 69: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in the FQHC• Same billing requirements as the office

– Reimbursement will be “encounter rate” and is all inclusive

– Encounters with more than one health professional and multiple encounters with the same health professionals which take place on the same day and at a single location constitute a single visit, except when one of the following conditions exist:

• (a) after the first encounter, the patient suffers illness or injury requiring additional diagnosis or treatment;

• (b) the patient has a medical visit and a clinical psychologist or clinical social worker visit.

Source: IOM 100-09, Chapter 1, Section 20.1

Page 70: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems

70

Page 71: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in the Hospital

• Outpatient– Both facility and professional fee

• E/M codes 99201-99215 (reported by both), and/or• SBIRT codes• If provided by health educator, payer and

employment drives coding and reimbursement

Page 72: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

SBIRT in the Hospital

• Inpatient– Facility fee = DRG

• No separate payment, “bundled in”

– Professional fee• E/M (99221-99223 or 99231-99233) and SBIRT

codes

– No separate payment for health educator

Page 73: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Ensuring Solutions to Alcohol Problems

73

Page 74: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

What is Incident-to??

Page 75: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

What is Incident-to?

It is a Medicare guideline ONLY!

“Incident to a physician’s professional services means that the services or supplies are

furnished as an integral, although incidental, part of the physician’s personal professional

services in the course of diagnosis or treatment of an injury or illness”

Page 76: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Five Key Concepts of “Incident-to”

1. Professional service

2. Location

3. Employment relationship

4. Incidental but physician/NPP performs initial service

5. Supervision, direct

Must meet all criteria for “incident-to”

Page 77: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Medicare’s Personal Performance Policy

• General rule– Physicians (and non-

physician practitioners NPP’s,) are only paid for what they personally perform and document

Page 78: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

An Exception to Medicare’s General Rule

• Incident to services are performed by personnel who are NOT physicians, but are paid for performing physicians services

Page 79: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Who can provide Incident-to services??

Page 80: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Definition of “Auxiliary Personnel”

• Auxiliary Personnel – “any individual” who is acting under the supervision of a physician…..

Page 81: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Auxiliary Personnel

• “Any individual” – CMS deliberately chose this term when defining “auxiliary personnel”– “So that the physician (or other practitioner), under his

or her discretion and license, may use the service of anyone ranging from another physician to a medical assistant.”

– “...impossible to exhaustively list all incident-to services and those specific auxiliary personnel who may perform each service.”

Federal Register/Vol. 66, No. 212/ Thursday November 1, 2001, pgs 55267 – 55268

Page 82: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Auxiliary Personnelvs. Practitioners

• Auxiliary Staff – Such as RNs, technicians, health educators and other aids

(not a complete list) – May meet criteria for 99211

• Practitioners/NPP– PA, NP, certified nurse midwife, clinical psychologists, clinical

social workers, certified registered nurse anesthetists and clinical nurse specialists

– Not restricted to level of E/M service or appropriate specialty code (must be within scope of practice)

Page 83: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

***Cautionary Note***

• Each occasion of service by auxiliary staff does not necessarily warrant the billing of a personal, professional service by the physician.

Page 84: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Where can you apply Incident-to?

Page 85: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

2. Location, Location, Location

• Physician’s office or clinic ONLY

• Applies to outpatient clinic setting but not outpatient hospital clinic setting

• No incident-to billing in an “institutional setting,” such as a hospital or a Skilled Nursing Facility (SNF)

Page 86: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Office within an Institution

• Must be confined to a separately identified part of the facility used solely as the physician’s office and – Cannot be construed to extend throughout the entire

institution

• Services performed outside the “office” area– Subject to the coverage rules outside the office

setting

Page 87: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

3. Employment Requirements

• May be a part-time, full-time or leased employee or independent contractor– Both the supervising physician and the

auxiliary personnel furnishing the service must meet the employment requirements

– Reassignment of benefits must be executed

Page 88: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

4. Initial Service Requirement

To bill incident-to, ‘there must have been a direct, personal, professional service furnished by a the physician to initiate the course of treatment of which the service being performed by the non-physician practitioner is an incidental part, and there must be subsequent services by the physician of a frequency that reflects his/her continuing active participation in and management of the course of treatment.’

Page 89: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Established Patient

“An established patient is one who has received professional services from the physician or another physician of the same specialty who belongs to the same group practice, within the past three years.” (CPT, 2009)

Page 90: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Established Plan of Care

• The personnel performing the incident-to service should:– Document the ‘link’ between their face-to-face

service and the preceding physician service to which their service in incidental.

– Reference by date and location the precedent providers’ service that supports the active involvement of the physician.

– Legible record both their identity and credentials

Page 91: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

5. Direct Supervision

“Direct supervision in the office setting does not mean that the physician must be present in the same room with his/her aide. However, the physician must be present in the office suite and immediately available to provide assistance and direction throughout the time the aide is performing the services.”

Page 92: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Direct Supervision – What it is

• Physician readily available in the office suite seeing patients in an adjacent exam room.

• There must be a specific physician responsible for the supervision of the billed service.

Page 93: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Direct Supervision –What it is not

• Physician doing rounds at the hospital and the auxiliary staff performing the service in the office.

• Physician having lunch downtown and is available by phone.

Page 94: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Supervising Physician

• The physician who performed the initial assessment and initiated the course of treatment does not need to be the physician supervising the incident-to service.

Page 95: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

CPT code 99211 & How to Bill Incident-to

(Medicare guideline)

Page 96: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

CPT code 99211

“Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services.” (CPT, 2009)

Page 97: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Criteria for billing 99211 as “incident-to”

• Must be an established patient

• There must be an established plan of care.

• There must be an E/M service provided by an employee of the physician.

• Must be provided in the office.

• There must be direct physician supervision.

Page 98: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Auxiliary Personnel

• Can only bill lowest level of E/M service, code 99211.

• Medicare will pay the claim at 100% of the physician fee schedule, even though the services were furnished by the auxiliary personnel. (health educator)

Page 99: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Non-Physician Personnel (NPP)

• Nurse Practitioner

• Nurse Midwife

• Clinical Nurse Specialist

• Physician Assistant

• Clinical Psychologist

• Clinical Social Workers

• Physical/Occupational Therapists

Page 100: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Non-Physician Personnel

• NPP can bill E/M levels 99211-99215.

• Medicare will pay the claim at 100% of the physician fee schedule, even though the services were furnished by the NPP.

• NPP’s can also establish the plan of care.– Health educators could bill 99211 “incident to”

a initial service provided by a NPP.

Page 101: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Performance of E/M Service

• No specific criteria in CPT for a 99211 (eg. level of history, exam or medical decision making).

• Face-to-face encounter with the auxiliary personnel and the patient consisting of both ‘evaluation and management’.

Page 102: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Documentation

• The medical record must be adequately documented to reflect the reason for the patient’s visit and any treatment rendered.

• The medical record must include elements of history obtained, examination performed and/or clinical decision making.

• The medical record must support physician supervision.

Page 103: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Summary

• Check for established patient and plan of care.

• Watch the location.

• Health educator must be employed by billing physician or NPP.

• Heed the supervision rules.

• Document, document, document.

Page 104: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

104

SBI Reimbursement Strategies

Providers can be reimbursed for SBI – even without specific codes.

http://www.ensuringsolutions.org/resources/resources_show.htm?doc_id=385233&cat_id=964

Page 105: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Facilitatedself change

Heavy drinking only

Chronic

Disease Management

Briefmotivationalcounseling

Medicalmanagement +pharmacotx or CBI

Specializedremission-orientedtreatment

Increased quantity, frequency & consequencesof alcohol use

Harmful drinking Dependence

Extended Continuum

Page 106: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

The extended continuum

Facilitatedself change

Moderate

Severe

Chronic

Disease Management

Briefmotivationalcounseling

Medicalmanagement +pharmacotx or CBI

Specializedremission-orientedtreatment

Widespread availability• Internet• Toll-free telephones (QUIT lines)• EAP & occupational health • Schools & workplaces• Primary care, hospital emergency departments• Criminal justice system

Page 107: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

The extended continuum

Facilitatedself change

Moderate

Severe

Chronic

Disease Management

Briefmotivationalcounseling

Medicalmanagement +pharmacotx or CBI

Specializedremission-orientedtreatment

Next step• Primary care• General MH care• Bulk of people needing

treatment are here

Page 108: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

The extended continuum

Facilitatedself change

Moderate

Severe

Chronic

Disease Management

Briefmotivationalcounseling

Medicalmanagement +pharmacotx or CBI

Specializedremission-orientedtreatment

SUD Specialty sector• Fully integrated with medical

and psychiatric care systems• Able to manage severe

co-morbidities• Disease management for

chronic or relapsing disorders

Page 109: Eric Goplerud, Ph.D. The George Washington University Medical Center Screening, Brief Intervention, Treatment and Recover Support: Getting Paid

Eric Goplerud, Ph.D.Director

2021 K St. NW, Suite 800Washington, DC

[email protected] .org

Center for Integrated Behavioral Health PolicyDepartment of Health Policy, The George Washington University Medical Center