As of 1/1/2017, CMS has made a change to the billing of moderate sedation during procedures in all specialties, including Pulmonary procedures.
Until this change, billing of moderate sedation was bundled in the billing code of the procedure itself. With this change, you will have to bill separately for your procedure and moderate sedation.

Here are the two possible scenarios for your practice and procedures:

Billing your procedures when using anesthesia services:

Pulmonologists or thoracic surgeons who use anesthesia professionals to provide sedation (deep sedation or general anesthesia) will see a reduction in the value of work RVU of their endoscopy procedures by approximately 0.25. In this instance, the anesthesiologist will bill separately for their sedation work and the pulmonologist will only bill for their endoscopy procedure.

Billing your procedures with moderate sedation:
There will be no financial impact for pulmonologists who perform their own moderate sedation. However, Pulmonologists performing their own moderate sedation for endoscopic procedures will now report separate codes for the procedure and for moderate sedation.

Below are the codes for moderate sedation in adults:

99152 – Moderate sedation services provided by the same physician or other qualified health care professional performing the diagnostic or therapeutic service that the sedation supports, requiring the presence of an independent trained observer to assist in the monitoring of the patient’s level of consciousness and physiological status; initial 15 minutes of intraservice time, patient age 5 years or older

99153 – Moderate sedation services provided by the same physician or other qualified health care professional performing the diagnostic or therapeutic service that the sedation supports, requiring the presence of an independent trained observer to assist in the monitoring of the patient’s level of consciousness and physiological status; each additional 15 minutes intraservice time (List separately in addition to code for primary service)

Please note that Intraservice time is used to determine the appropriate CPT code to report moderate sedation service duration. Intraservice time starts with administration of the sedation agents, requires continuous face‐to‐face attendance, and ends at the conclusion of personal contact by the physician providing sedation.

Documentation of moderate sedation service should contain the following elements:

  • Physician/patient face-to-face sedation start time
  • Physician/patient face-to-face sedation stop time
  • Total moderate sedation time in minutes
  • Attestation that patient was monitored continuously 1:1 throughout the entire procedure by the physician while sedation was administered

A few caveats to consider:

The nurse or other staff can inject the sedation drug at your direction when you are in the room and you do not have to inject the drug yourself

You have to reach at least 10 min of moderate sedation to bill the first code (99152). If the duration of moderate sedation is less than 10 minutes, you cannot bill for it.

For the 99153 code, you use it to bill for each additional 15-minute increment of moderate sedation. Each subsequent increment used must be at least 8 minutes to justify billing an additional 99153 code (see example below).

Case example:

You just finished a flexible bronchoscopy on a patient with right lung mass and mediastinal adenopathy. You performed EBUS-TBNA on 4L lymph node and got the diagnosis of adenocarcinoma. Your total moderate sedation time was 49 minutes.

You documented the following:

  • Physician/patient face-to-face sedation start time: 1:00 pm
  • Physician/patient face-to-face sedation stop time: 1:49 pm
  • Total moderate sedation time in minutes: 49 minutes

You should bill as follows:

  • 31652 EBUS-TBNA of 1-2 lymph nodes
  • 99152 Moderate sedation first 15 minutes
  • 99153 Moderate sedation additional 15 minutes
  • 99153 Moderate sedation additional 15 minutes

You cannot bill the last 4 minutes of moderate sedation as this duration does not meet the minimum requirement of 8 minutes for incremental billing.

As always, it is best to confirm all regulatory requirements for documentation, coding and billing with your practice’s revenue or business manager to ensure compliance with CMS requirements.

If you have any questions, please direct them to Dr. Momen Wahidi

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