There it is again! One more department manager freaking out because his or her hospital administration is insisting that “one (patient) encounter is considered the entire hospital stay.” Administrators decry the consequences of this line of thinking, when they say, “If we have a patient ordered on QID treatments who is here for five days, we can only bill for the first treatment that we gave and the rest are written off during the entire hospital stay.”
In a previous post regarding CPT 94960 and this whole patient encounter interpretation snafu, I posed that one has to critically ask the questions, “Is CMS intentionally trying to put respiratory therapy departments out of business? How does this improve care for COPD patients and reduce 30-day readmissions? Are we really damned if we do and damned if we don’t, or is there just a need for reasoned, level-headed interpretation of the guidelines while we await forthcoming regulatory clarification?”
Well, as it turns out, the final clarification on what constitutes a patient encounter came from CMS in 2014! In an official letter from CMS to the AARC, Dr. Niles Rosen, who is the medical director for the National Correct Coding Initiative (NCCI), cited the Code of Federal Regulations (42 CFR 410.2). He elucidated emphatically that an encounter means “direct personal contact between a patient and a physician or other person who is authorized by state law and, if applicable, by hospital or CAH staff bylaws, to furnish hospital services for diagnosis or treatment of the patient.” This has also been noted in the AARC Coding Guidelines for Certain Respiratory Care Services, which was updated for 2016.
So there you have it. We can continue to charge for one administration of CPT code 94960 for each direct patient contact in which therapy is administered. Whew! That was close! It’s good to know that CMS is not trying to put us out of business. Now, it is up to us to not let some misinformed hospital finance executive do so as well.