We asked CPT for direction on how to report days two and three of that stay. As published in the July 2019 issue of CPT Assistant, the AMA instructs physicians to report the appropriate ED E/M code, initial observation code (99218–99220) or critical care code, depending on the chart documentation, for the first day in the emergency department. For day two, CPT instructs us to use a subsequent observation day code (99224–99226) to capture the middle day (or multiple days) of a prolonged behavioral health stay in the ED setting. On the day of discharge from the ED setting, the discharging physician should report the appropriate subsequent observation day or the discharge from observation code (99217) based on the level of service documented.
Of note: Third party payment policies and unique contractual language may differ from CPT coding direction.
These new directions from CPT are helpful, as previously there was no way to report the extra days of care for the patients described here.
Table 1: Relative Value Units (RVUs) and Payments for Additional Mental Health Bed Hold Daily ED Services
|CPT Code||2019 Facility Total RVU||2019 Medicare Payment|
This represents an important win in our shared battle to improve support and funding for mental health care.
Previously: 99285 on day one and no charges for days two through five.
Total five day stay: 4.89 RVUs
Updated: 99220 day one (5.23 RVUs), 99225 days two through 4 (3 X 2.06 RVUs), day five 99217 (2.06 RVUs)
Total five day stay: 13.47 RVUs
Resources for these and other topics can be found on the reimbursement section of the ACEP website. ACEP Director of Reimbursement David McKenzie, CAE, is also available to field your questions at 800-798-1822, ext. 3233 or firstname.lastname@example.org. ACEP offers well-attended and highly recommended coding and reimbursement educational conferences annually, with an offering in January 2020 in Austin, Texas.
- Laderman M, Dasgupta A, Henderson R, Waghray A. Tackling the mental health crisis in emergency departments: look upstream for solutions. Health Affairs website. Published Jan. 26, 2018. Available at https://www.healthaffairs.org/do/10.1377/hblog20180123.22248/full/. Accessed Sept. 10, 2019.
Dr. Granovsky is President of LogixHealth, an ED coding and billing company, and currently serves as the course director of ACEP’s Coding and Reimbursement courses. He can be reached at email@example.com.