FREQUENTLY ASKED QUESTIONS



THIS PAGE UPDATED MARCH 22, 2008




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  • Q. What are the credentials CSS after your name?
  • A. Many years ago, I came to the conclusion that the majority of coding rules, reimbursement strategies and techniques used to increase income while avoiding audits could be easily understood using common sense. Consequently, I began a quest to become certified in this area and discovered that there was no agency or organization devoted to this purpose. So, I created the credentials CSS for Common Sense Specialist and bestowed it upon myself.


  • Q. Can I bill for two E&M visit codes in one day?
  • A. Yes, you definitely can bill for two. Now, whether you get paid for two or not depends on several factors, including the reason for each visit, whether the reasons are related to each other, the type of payer (Medicare, private, mangled care, etc) and how well you document. Medicare does not allow two E&Ms on the same day for the same reason, although some private carriers do. When in doubt,k make sure your documentation supports what you did and then bill for it.


  • Q. My husband has been unemployed for several years and treats me without respect. Since our daughter moved away, he rarely even talks to me. What should I do?
  • A. You need to grow up and quit whining. It's time to dump the guy. You're a New York Senator, so you need to act like it.


  • Q. If I bill for two E&M codes on the same day, should I use modifier 25 on one or the other?
  • A. There was a time when I would recommend using the 25 modifier, but after seeing a communique between a colleague (Greg Schnitzer) and CMS, I now recommend using modifier 59 on BOTH.


  • Q. I've heard that cardiovascular exercise can prolong life. Is this true?
  • A. Your heart is only good for so many beats, and that's it...don't waste them on exercise. Everything wears out eventually. Speeding up your heart will not make you live longer; that's like saying you can extend the life of your car by driving it faster. Want to live longer? Take a nap.


  • Q. Do all insurance carriers use the same rules concerning global fees?
  • A. Unfortunately, each carrier or payer can make up their own rules when it comes to global fee periods and what is considered part of the global. I have been using Medicare's global fee periods for years and pretty much expect the carriers I deal with to do the same. You can download the global fee periods on my Documents page.


  • Q. Why do round pizzas come in square boxes?
  • A. That's easy. If the boxes were round, they would rotate around while sitting in the passenger seat on the way home - thereby spilling the pizza.


  • Q. I saw an ad in a magazine that I can own my own billing service and make $100,000 a year by the 2nd year if I buy a software program and attend a course. Do you recommend these programs?
  • A. The day that Hillary Clinton becomes a firm believer in smaller government will be the day that I recommend these programs. Most of these that I've seen are (in my opinion) a rip-off of your hard earned money. It takes time, training and usually a mentor, for someone to learn the billing business and it's not a get rich quick business. You will work your butt off before you get rich in this business.


  • Q. Taking insurance only and routinely waiving co-pays on employees is illegal, but what about not charging the employee or their insurance at all for services?
  • A. It is not illegal to write off co-pay. There is no law passed by Congress or any state legislature that I know of saying it's illegal. Now - with that said - let me also say that you can be sued in civil court for things that are legal - and in this case, it is possible that you could get sued by an insurance carrier for not following contractual obligations. Of course, you could also be sued for not calling someone an Antarctic-American if their great great great grandfather moved here from Antactica by someone who is adamant about being a hyphenated American. Heck - you can be sued for anything in this country, regardless of how ludicrous the suit is. I have heard of cases where insurance carriers sued providers for routinely waiving the co-pays. I have NEVER heard of anyone being sued for not collecting co-pays from their own employees and I've never talked to anyone who has (trust me when I say this conversation comes up frequently on legal-health listservs). So - while it's not illegal - you can be sued. The fact that I've never heard of anyone being sued for this when dealing with employees tells you that the chances of being sued is probably equal to the chances that Hillary will get the endorsement of Jerry Falwell in 2008.

  • Q. If a Medicare patient comes into the office only for a blood pressure check, can we bill code 99211 if there is no physician in the office?
  • A. No. To meet Medicare's “incident to” criteria for this code, a physician must be in the office suite. If the person administering the injection is a Nurse Practitioner and they have their own Medicare Part B provider number, then you can bill using that PIN. Now - if it's not Medicare - it depends on the carrier. CPT rules do not require the physician be on the premises - although your malpractice carrier may.


  • Q. How do I bill for prolonged physician services, procedure code 99354?
  • A. Procedure code 99354 must be billed in conjunction with E/M codes 99201-99215, 99241-99245, or 99301-99350. Prolonged services can be billed only if the total duration of all physician direct face-to-face services (including visit) equals or exceeds the threshold time for the E/M service the physician provided (typical time plus 30 minutes). If the total duration of direct face-to-face time does not equal or exceed the threshold time for the level of E/M service the physician provided, the physician may not bill for prolonged services.


  • Q: Should I cut down on meat and eat more fruits and vegetables?
  • A: You must grasp logistical efficiencies. What does a cow eat? Hay and corn. And what are these? Vegetables. So a steak is nothing more than an efficient mechanism of delivering vegetables to your system. Need grain? Eat chicken. Beef is also a good source of field grass (green leafy vegetable). And a pork chop can give you 100% of your recommended daily allowance of vegetable products.

  • Q. Can a provider in a group practice charge for services provided to an immediate family member of one of the other providers in the same group practice?
  • A. Yes. Medicare does not cover services provided to an immediate relative or member of the household. However, if the service is provided for another provider, it is considered a covered service.


  • Q. My spaghetti always sticks together after I boil the noodles and drain them. What can I do to help that?
  • A. I always put about a teaspoon of Olive Oil in the pan of water before adding the noodles and they do not stick together.


  • Q. Is it true that I can't bill Medicare more than I charge someone else? In other words, can I give discounts when I want to?
  • A. No - it's not true that you can't ever bill anyone less than Medicare. Medicare has a rule that says a physician cannot routinely and substantially charge Medicare more than other payers and officials at CMS have stated that routinely is "45% of your patients", and "substantially" has been defined as more than 30% more to Medicare than others. So - if you put this together, you come up with the fact that if you do not charge 45% of your patients more than 30 % more than Medicare, you don't have a problem. Now - where do you find this? Look it up in CMS' website or send me money to copy you on letters. This is free - and you nomally get what you pay for. It's ok to give discounts - just DON'T take insurance only and routinely waive co-pays and deductibles on anyone other than employees of YOUR practice.


  • Q. I've sent you emails, but you never replied. Do you read your emails?
  • A. I get more than 600 emails a day. Now, it's sad, but about 200 of them are trying to get me to buy the latest gizmo, drug or cream to make certain body parts larger - and when I first started getting those, I wondered who my wife had talked to when she had promised me that size doesn't matter, bu then I realized that everyone gets those. Yes, I do read them - bit it's possible that your email has something in it that may have prompted my SPAM killer software to delete it. It's also probable, if you use an AUTORESPONDER when you're not at your computer, that your autoresponder prompted my computer to permanently ban your email address from my in-box. You see, some people feel SO IMPORTANT that they believe they have to tell the world when they are going potty or taking time off they they set up an AUTO RESPONDER to autoreply to incoming emails. Now - don't misunderstand, as I have nothing against egos as I have a large one myself (does size really matter?), but if you are on a listserv and have it turned on, it replies to EVERY listserv telling people that you took time off to have your toenails painted, or whatever you have it say. If a listserv generates 100 emails a day, then YOU'VE just doubled it. If you're on 14 listservs as I am - and 5 people on them have autoresponders on - that can quadruple the number of emails I get. Therefore I set up my system to autoblock an email addresses FOREVER that sends me an email with AutoReply or Autorespond in the subject line. That's too bad - but people should know better.


  • Q. What do women really want?
  • A. Why ask me? I've been married for 25 years and I have absolutely no idea!

  • Q. What do men really want?
  • A. Duh - that's easy. WOMEN!




  • Q. If I admit a patient into observation one day and then admit them into in-patient the next day, does the patient's admit become retroactive to the first date?
  • A. It doesn't matter if a patient stays 23 hours, less than 23 hours, 48 hours or 72 hours. If the patient is out-patient (place of service 22), because THAT is where the doctor admitted the patient, then they are out-patient. To retroactively admit the patient in-patient, when the doctor did not feel the patient met DRG requirements to be in-patient, could be considered by some (including moi) to be fraudulent billing. So - in answer to your question, you should use 99218, 99219 or 99220 on the first date (regardless if the patient is admitted at 6:15am or 11:47pm). Then, on the second date, bill out-patient codes 99211-99215 for EACH visit the doc makes to the patient in observation (still with POS 22) UNLESS the doc either admits the pt into IN-PT status or sends the patient home (or they kick off as Greg House MD phrased it last week). In the case of the admit into IN-PT status, you would have a 99221 or 99222 on the 2nd day with the POS 21. Yes, it's conceivable you could get a 99223 on that admit - but doubtful since most doctors will not do a completely NEW history, exam and mdm on the patient, but rather they would use the data from the admit into obs the previous day to dictate an in-pt admit. You would NOT use an out-patient visit code 99211-99215 on that date. In the case of discharging the patient home (or to the morgue, if patient expired), you would use a 99217 that date, again - not billing any 99211-99215 that date.




  • Q. Has Medicare changed the G0001 code? I'm getting denials.
  • A. Yes, as of January 1st, 2005, it was deleted. Medicare expects you to use the 36415 code now.




  • Q. Can the nurse document the ROS, HPI or PFSH?
  • A. Interesting question. If you believe the majority of coders asked, the answer is (by some - but not all) that the doc has to record their own HPI - but the nurse (or anyone else) can record the PFSH and ROS. My viewpoint is the same as Bart McCann (who works for the entertainer formerly known as HCFA - but now known as CMS - which should be CMMS since it stands for Centers for Medicare "and Medicaid" Services) who was quoted in an April 27, 1998 Part B News as being asked "Is it allright, under the new E&M documentation guidelines for ancillary staff to take the history of present illness?". Mr. McCann's quote is: "Yes, if the doctor reviews and signs the history and supplements it, as needed". He also said: "But, remember that just signing it is not enough. Doctors must write "I have reviewed and I agree', or Medicare carriers won't assume that the doctor reviewed the history." As Jo Ann Steigerwald pointed out, this is a revision of a previous answer by him in late 1997 where he said that physicians must document their own HPI, so I guess that is good news for the doctors. Jo Ann also pointed towards one of the Medicare carriers' FAQ page where they are in contradiction to the CMS official quoted above, at http://www.wpsic.com/medicare/provider/doc_faq.shtml . This is a perfect example of the GAO STUDY RELEASED IN JULY 2004: “During our test calls, Medicare Customer Service Representatives typically provided incorrect and incomplete answers to the 300 policy-oriented questions we posed. Only 4 percent, or 12 OUT OF 300 responses were correct and complete." I also strongly recommend you immediately go to PART B NEWS from DECISIONHEALTH and subscribe to this very worthwhile subscription - which can help keep you out of trouble.



  • Q. Can my doctor bill for the interpretations of EKGs and X-rays done in the ER when the radiologist or cardiologist will be doing an over-read?
  • A. The doctor that makes the decisions about the patients care AND provides a written professional interpretation gets to bill for the x-ray or ekg interp. See Medicare Carrier Manual Section 15023 about this subject.

  • Q. Do I have to provide an interpreter at my own expense when I see a deaf patient or can I use other means of communications?
  • A. The AMA has an excellent resource on this at http://www.ama-assn.org/ama/pub/category/4616.html that says the doctor gets to determine when an interpreter or other alternative is required to ensure the proper communication. They state that some instances will require the use of a qualified interpreter moreso than others. Some minor problems may only require a pen and paper or a family member, while some may require the use of an interpreter. In no instance, do we at Don Self & Associates recommend you pay the interpreter the patient chooses or brings with them - as too many scams occur this way. If you are going to get an interpreter - get your own.

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