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November 4, 2003

CPT 2004 AND STARRED (*) PROCEDURES

The new CPT coding principles become effective January 1, 2004. A substantive change with significant potential consequences for Emergency Medicine pertains to deletion of the Starred (*) Procedure concept from CPT. The best way to highlight the changes is to compare the current coding principles (CPT 2003) and the new ones (CPT 2004).

CPT 2003

Currently CPT recognizes two types of surgical procedures: Starred and "non-starred". For "non-starred" surgical procedures, the CPT Surgical Package is included in the procedure, and encompasses: a) essentially any non-general anesthesia required for the procedure, b) an E/M service subsequent to the E/M service at which the decision for surgery was made, c) immediate post-operative care, d) writing orders, e) evaluating the patient in the postanesthesia recovery area, and f) typical postoperative follow-up care. However, the Surgical Package concept is not applicable to Starred Procedures. Therefore, any components of the Surgical Package provided while performing a Starred Procedure can be coded separately (e.g., non-general anesthesia for which there is a CPT code, typical postoperative care including wound checks and suture removal, etc.)

When the Surgical Package is applicable, an E/M service provided during the same encounter, or on the same day, as a "non-starred" procedure can be separately coded only when:

  1. The patient's condition required a significant, separately identifiable E/M service above and beyond the other service provided or beyond the usual preoperative and postoperative care associated with the procedure that was performed. The E/M service may be prompted by the symptom or condition for which the procedure and/or service was provided. As such, different diagnoses are not required for the reporting of the E/M services on the same day. When such an E/M service is reported, it can be identified by appending a "-25" modifier.

  2. The E/M service is the one that resulted in the initial decision to perform the surgery. When such an E/M service is reported, it can be identified by appending a "-57" modifier.

Because Starred Procedures are not encompassed by the Surgical Package concept, E/M services provided at the same encounter (or on the same day) as a Starred Procedure, can be separately reported without any need for a modifier. (CPT identifies two non-standard E/M codes for this purpose. However, in a separate letter communication CPT has indicated that in the ED, the ED E/M codes are to be used.)

It is worthwhile noting that Medicare does not utilize the Starred Procedure concept, and instead assigns specified "global periods" (i.e., 0, 10, and 90 days) to procedures, and then categorizes such procedures as "minor" (i.e., a global period of 10 days or less) and "major" (i.e., a global period of more than 10 days). By policy, Medicare will only recognize an E/M service reported with a "minor" procedure if such E/M has a "-25" modifier appended. Generally, Medicare will not recognize any E/M service reported with a "minor" procedure if a "-57" modifier is appended, or if no modifier is appended. For "major" procedures, Medicare will recognize an accompanying E/M service with either a "-25" or a "-57" appended. Generally, however, Medicare will not recognize an E/M service accompanying a "major" procedure if the E/M service has no modifier appended.

CPT 2004

Inasmuch as the Starred Procedures category is eliminated, all procedures will be encompassed by the Surgical Package concept. Therefore, the requirements described for "non-starred" procedures above will now pertain for all surgical procedures.

Inasmuch as Medicare coding has not incorporated the Starred Procedure concept, there will be no change for Medicare code reporting.

The greatest potential impact of this revision is in the 2004 CPT coding of any E/M service accompanying a surgical service. While the rules for "non-starred" procedures are not new, they are somewhat removed from Emergency Medicine due to the previous applicability to services not usually performed by Emergency Medicine practitioners. As such, these practitioners might be perplexed by having to make the necessary distinctions among "E/M-25," "E/M-57," and those E/M-like activities that might not be separately reportable.

And, once again, the effect of the CPT 2004 Starred Procedure elimination upon relevant E/M coding for Medicare patients should, at worst, be negligible.

   
 
 
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