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September 24, 2023

CPT® and CMS rules for critical care | What’s the difference?

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Bad news in 2023

CMS issued a “technical correction” in the 2023 PFS Final Rule. They stated that it is their policy that add-on code 99292 can only be reported when critical care time is 104 minutes, not 74 minutes as stated in CPT®. CMS noted they stated this in the 2022 proposed rule, but the 2022 Final Rule incorrectly used the CPT® time chart.

For Medicare patients, the full 30 minutes of 99292 must be met in order to use the code, not the midpoint (15 minutes) of the code.

For Medicare patients:

  • Use 99291 from 30 minutes until 103 minutes.
  • Add on code 99292 only if the time meets 104 minutes.

[The] total time spent by the practitioners could be aggregated to meet the time
requirement to bill CPT code 99291. Under this proposal, once the cumulative required
critical care service time is met to report CPT code 99291, CPT code 99292 could not
be reported by a practitioner in the same specialty and group unless and until an
additional 30 minutes of critical care services are furnished to the same patient on the
same day (74 minutes + 30 minutes = 104 total minutes).”

“Thereafter, the physician or NPP would report CPT code 99292 for additional 30-
minute time increments provided to the same patient.”

2023 PFS Final Rule, page 675.

CodingIntel members can download the Critical Care Coding Guide for more detail.

 



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Last revised December 14, 2022 - Betsy Nicoletti
Tags: critical care services

CPT®️️ is a registered trademark of the American Medical Association. Copyright American Medical Association. All rights reserved.

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Our mission is to provide up-to-date, simplified, citation driven resources that empower our members to gain confidence and authority in their coding role.

In 1988, CodingIntel.com founder Betsy Nicoletti started a Medical Services Organization for a rural hospital, supporting physician practice. She has been a self-employed consultant since 1998. She estimates that in the last 20 years her audience members number over 28,400 at in person events and webinars. She has had 2,500 meetings with clinical providers and reviewed over 43,000 medical notes. She knows what questions need answers and developed this resource to answer those questions.

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