2022 Medicare Critical Care Updates

June 20, 2022

By Stacie Norris, CCS-P, CPC, Director, Coding Quality Assurance

The 2022 Medicare Physician Fee Schedule (MPFS) Final Rule contained some significant changes to the Medicare guidelines on Critical Care coding and billing. The CPT codes for Critical Care services are as follows:

CMS changed their policy to be more in-line with CPT’s guidelines on Critical care and officially adopted many of the CPT Critical care guidelines.  For example, CMS stated in the MPFS Final Rule that NPPs (non-physician practitioners) can also report Critical care services, which is in-line with CPT. CMS also adopted the CPT rule to report any situation where services extend from one day to the next:

Regarding critical care services crossing midnight, CPT guidance defines how a service is to be billed when the service extends across calendar dates. For continuous services that extend beyond midnight, the physician or NPP will report the total units of time provided continuously. Any disruption in the service, however, creates a new initial service. We are adopting this rule for critical care being furnished by a single physician or NPP when the critical care crosses midnight.

In addition to the above changes, CMS also included the following in the MPFS Final Rule:

  • Critical care and Concurrent care: Same-day Emergency Department, Inpatient or Office/Other Outpatient Visits – Critical care services may be paid on the same day as other E/M visits by the same practitioner or another practitioner in the same group of the same specialty, if the practitioner documents that the E/M visit was provided prior to the critical care service at a time when the patient did not require critical care, the visit was medically necessary, and the services are separate and distinct, with no duplicative elements from the critical care service provided later in the day. Practitioners must report modifier -25 on the claim when reporting these critical care services. 
  • Critical care services can now be furnished as split (or shared) visits. The substantive portion for critical care services is defined as more than half of the total time spent by the physician and NPP. To bill split (or shared) critical care services, the billing practitioner first reports CPT code 99291 and, if 75 or more cumulative total minutes are spent providing critical care, the billing practitioner reports one or more units of CPT code 99292.
  • Critical care and global surgery change: When the critical care service is unrelated to the procedure, append the modifier -FT ((unrelated evaluation and management (E/M) visit on the same day as another E/M visit or during a global procedure

Stay tuned for more critical care updates from Zotec Partners, especially as we continue to track and research MPFS and upcoming E/M code changes to the specialty in 2023.