If I am an ICU attending taking care of a sick patient and I take them to the OR to do a case, can I bill for both "critical care time" in the ICU and ASA units associated with the OR case? I think the answer is no but I am not sure...
Disclaimer not an anesthesiologist but someone who teaches PA CCM billing.
My answer would be probably. Medicare separates out bundled and non-bundled services. You can bill for things that are not bundled into critical care as long as you don't count that time for critical care. For example if you put in an art line the time doesn't count for critical care time but you can bill the procedure separately. It would be a similar situation with surgery. If someone for example needed a port removed it could be done by a surgical critical care attending in the ICU and the procedure would be billed for. Critical care for that period would be billed for with a -25 modifier to identify it as separate and distinct critical care services (see here section K):
https://www.cms.gov/transmittals/downloads/R1530CP.pdf
Also consider this:
J. Critical Care Services and Other Procedures Provided on the Same Day by the Same Physician as Critical Care Codes 99291 – 99292
The following services when performed on the day a physician bills for critical care are included in the critical care service and should not be reported separately:
•The interpretation of cardiac output measurements (CPT 93561, 93562);
•Chest x-rays, professional component (CPT 71010, 71015, 71020);
•Blood draw for specimen (CPT 36415);
•Blood gases, and information data stored in computers (e.g., ECGs, blood pressures, hematologic data-CPT 99090);
•Gastric intubation (CPT 43752, 91105);
•Pulse oximetry (CPT 94760, 94761, 94762);
•Temporary transcutaneous pacing (CPT 92953);
•Ventilator management (CPT 94002 – 94004, 94660, 94662); and
•Vascular access procedures (CPT 36000, 36410, 36415, 36591, 36600);
No other procedure codes are bundled into the critical care services. Therefore,
other medically necessary procedure codes may be billed separately.
Anesthesia just like intubation is not listed as a bundled service. I would think that its billable. You would probably need a -25 code for the CCM time in order bill separately. At least thats what our CCM anesthesiologists seem to do. Of course the cleanest way to do things is to make sure you are either anesthesia or CCM on a given day.
