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Background
Emergency Department (ED) visits should be coded based on hospital resource utilization which is dictated by the patient’s clinical condition and the treatment provided. There are five visit levels that the ED can choose from when submitting claims. Visit level 1 is the least resource-intensive for the facility and visit level 5 is the most resource-intensive. These visit levels are represented by the following Evaluation and Management (E&M) procedure codes:
Procedure Codes and Corresponding Levels for ED Claims
| Visit Level | Procedure Codes* | Explanation |
|---|---|---|
| 1 | 99281/G0380 | Used for very simple and limited services. The presenting problem is usually self-limited or minor. |
| 2 | 99282/G0381 | Typically assigned for an acute episodic illness and/or minor injury evaluation. The presenting problem is of low to moderate severity. |
| 3 | 99283/G0382 | Generally requires additional facility resources including x-ray, laboratory testing or additional nursing time. The presenting problem is of moderate severity. |
| 4 | 99284/G0383 | For encounters associated with acute illness or injury that requires prolonged evaluation and typically diagnostic studies, repeat nursing evaluations, or other therapeutic interventions. The presenting problem is high severity requiring urgent evaluation. |
| 5 | 99285/G0384 | For encounters that are associated with serious presenting symptoms, often a life-threatening disease or injury, requiring treatment that is complex and/or resource intensive. The presenting problem is of high severity and/or poses an immediate significant threat to life or physiological function. |
*Procedure codes starting with “9” above, are considered Type A codes and procedure codes starting with a “G” above are considered Type B codes. “[CMS] considers the main distinguishing feature between Type A and Type B emergency departments to be the full-time versus part-time availability of staffed areas for emergency medical care, not the process of care or the site of care (on the hospital’s main campus or offsite),” per the CY 2008 OPPS Final Rule (referenced below).
At the time of the introduction of the Medicare Outpatient Prospective Payment System (OPPS) and the associated ED Ambulatory Payment Classifications (APCs), Medicare did not specify a standard approach for classification of the acuity levels for ED E&M visit codes. Instead, facilities were instructed to use any methodology as long as it met certain Centers for Medicare and Medicaid Services (CMS) guidelines. Per the current CMS guidelines (CY 2008 OPPS Final Rule (Medicare and Medicaid Programs; Interim and Final Rule) published in the Federal Register on November 27th, 2007) the facility must bill the visit level that most reasonably relates to the intensity of hospital resources used in the treatment of the patient.
CMS Guidelines
| CMS Guidelines | |
|---|---|
| 1 | Follow the intent of the CPT® code descriptor in that the guidelines should be designed to reasonably relate the intensity of hospital resources to the different levels of effort represented by the code |
| 2 | Be based on hospital facility resources, not on physician resources |
| 3 | Be clear to facilitate accurate payments and be usable for compliance purposes and audits |
| 4 | Meet the HIPPA requirements |
| 5 | Only require documentation that is clinically necessary for patient care |
| 6 | Not facilitate upcoding or gaming |
| 7 | Be written or recorded, well documented and provide the basis of selection of a specific code |
| 8 | Be applied consistently across patients in the clinic or emergency department to which they apply |
| 9 | Not change with great frequency |
| 10 | Be readily available for fiscal intermediary (or if applicable, MAC contractor) review |
| 11 | Result in coding decisions that could be verified by other hospital staff, as well as outside sources |
The goal of the Optum EDC Analyzer™ is to achieve fair and consistent E&M coding and reimbursement of facility outpatient ED claims. The EDC Analyzer™ systematically evaluates each ED visit code in the context of other claim data (i.e., diagnosis codes, procedure codes, patient age, and patient sex*) to determine if it reasonably relates to the intensity of utilized hospital resources. The methodology used by the EDC Analyzer™ is based on Optum's Lynx™ Charge Capture (OCC) tool, which is used by 1,500 facilities nationwide to code outpatient emergency department claims. This idea of a shared methodology for both payers and providers underscores Optum's commitment to simplify the health care system, and promote transparency in the coding and reimbursement process.