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Question: What information must a teaching physician include when reporting code 99291?

Answer: The Centers for Medicare and Medicaid Services (CMS) Transmittal 1548 significantly changed the teaching physician’s documentation requirements for critical care encounters with resident participation. Physician documentation of total critical care time alone is not enough to support reporting Current Procedural Terminology (CPT) code 99291.

The teaching physician may refer to the resident’s documentation for specific patient history, physical findings, and medical assessment. However, the teaching physician’s documentation must provide substantive information as well, including:

• The total time (in minutes) the teaching physician spent providing critical care
• That the patient was critically ill during the time the teaching physician saw the patient
• What made the patient critically ill
• The nature of the treatment and management provided by the teaching physician

Time spent teaching may not be counted toward critical care time, and Medicare auditors might not accept simply adding critical care time to the normal teaching physician attestation. In a recent audit, the following attestation was not allowed for reporting code 99291: “40 minutes of critical care time provided, exclusive of separately billable procedures. I was present with the resident during the history and exam. I discussed the case with the resident and agree with the findings and plan as documented in the resident’s note.”

In contrast, the following CMS example includes acceptable teaching physician critical care documentation: “The patient developed hypotension and hypoxia. I spent 45 minutes while the patient was in this condition providing fluids, pressor drugs, and oxygen. I reviewed the resident’s note and concur with their findings.” 

Brought to you by the ACEP Coding and Nomenclature Committee.

Dr. Thomas is president of ERcoder, Inc.