What E/M code would you bill for initial evaluation at an “inpatient” acute care facility in a long term, rehabilitation unit? What “place of service” would you use?
When patients receive their hospital discharges after a critical illness or injury, but still need care, several types of facilities can help them transition from the hospital back to their homes. There are three potential areas of service that can be involved with respect to the posted scenario:
- 1. Long-term acute care facilities (LTACHs)
- 2. Skilled nursing facilities (SNFs)
- 3. Inpatient Rehabilitation Facility (IRF)
A Long-term acute care facility: This term refers to a hospital-grade facility for patients who are still ill enough to require a high level of complex care. These patients do not need to stay in the hospital in the intensive care unit or for emergency treatment — their health is relatively stable — but they still require a more sophisticated level of care than many other facilities can provide. An LTACH delivers more or less a continuation of hospital-level care in a longer-term setting. This is best identified with POS code 21: Inpatient Hospital.
A skilled nursing facility : is another common stopping point for patients after they get discharged from the hospital. A skilled nursing facility is usually right for patients who do not need the intensive level of care offered by a long-term acute care facility but still require medical care and support before they can live on their own. This is best identified with POS code 31: Skilled Nursing Facility.
An Inpatient Rehabilitation Facility: provides intensive, innovative therapeutic and rehabilitative care to help patients regain functions after a severe injury or illness. Patients live at the inpatient facility and receive intensive daily therapy to help strengthen and repair their bodies. At these facilities, caregivers expect patients to commit to rehabilitation sessions of at least three hours of therapy a day, five days a week. This is best identified with POS code 61: Comprehensive Inpatient Rehabilitation Facility.
For the purpose of the posted scenario, a Long-term acute care facility, POS code 21 would be the appropriate choice to make.
With respect to the E/M code to bill for the initial evaluation of a patient at the facility, the best choice would be the E/M codes for Hospital Inpatient Services. For initial inpatient hospital encounters by physicians other than the admitting physician, the subsequent hospital care codes would be utilized as appropriate. It is important to remember that these E/M codes are NOT based upon the 2021 E/M coding changes. They are still based upon the 1995/1997 E/M Guidelines.
99231: Subsequent hospital care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components; a problem focused interval history, a problem focused examination, and medical decision making that is straightforward or of low complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is stable, recovering or improving. Physicians typically spend 15 minutes at the bedside and on the patient’s hospital floor or unit.
99232: Subsequent hospital care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components; an expanded problem focused interval history, and expanded problem focused interval history, an expanded problem focused examination, and medical decision making of moderate complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is responding inadequately to therapy or has developed a minor complication. Physicians typically spend 25 minutes at the bedside and on the patient’s hospital floor or unit.
99233: Subsequent hospital care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components; a detailed interval history, a detailed examination, and medical decision making of high complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is unstable or has developed a significant complication or a significant new problem. Physicians typically spend 35 minutes at the bedside and on the patient’s hospital floor or unit.
This is my opinion.
Michael G. Warshaw
DPM, CPC
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