COMPLIANCE PROGRAM FOR SMALL PRACTICES
Are small practices (e.g., 1–5 physicians) required to have billing and coding compliance programs?
Yes, but the program can be scaled down to reduce the burden on the practice. The U.S. Department of Health and Human Services Office of Inspector General provided advice for solo and small practices in its 2023 General Compliance Program Guidance. The guide offers suggestions and training videos to help practices establish a compliance program to protect against fraud, waste, and abuse that is adapted to their organizational structure and available resources. For example, small practices likely cannot financially support a full-time compliance officer but can instead designate one person as their compliance contact responsible for ensuring the practice completes compliance activities.
TUBERCULOSIS SKIN TEST
What codes should I report for administering a tuberculosis skin test?
Report CPT code 86580 for intradermal injection of the purified protein derivative skin test. This code includes both the administration of the injection and the antigen product itself. Link 86580 to ICD-10 code Z11.1, “Encounter for screening for respiratory tuberculosis” when you perform the test absent a clinical indication (e.g., possible exposure to tuberculosis).
When clinical staff provide a follow-up visit to evaluate the injection site for reaction, you can report that with 99211 (E/M visit that does not require a physician’s presence). “Incident-to” policies may apply to that visit, depending on the payer. If the reaction indicates a potential positive test result, that may require a physician’s evaluation and a higher level of E/M.
HOSPITAL CARE FOR PATIENT WITH INFECTIOUS DISEASE
As a family medicine hospitalist, can I report HCPCS code G0545 for visit complexity inherent to hospital inpatient or observation care when managing a patient who has an infectious disease?
Typically not. Only physicians with specialized training in infectious disease (ID) who have enrolled in Medicare with an ID specialty (e.g., ID specialty code 44 and taxonomy code 207RI0200X0) can report G0545 in addition to a code for inpatient hospital care (e.g., 99221-99233).
G2211 WITH ADVANCE CARE PLANNING
Is it appropriate to report HCPCS add-on code G2211 for visit complexity with advance care planning (CPT codes 99497-99498) if I did not provide an office E/M service on the same date?
No. Code G2211 is an add-on code that should be reported only with E/M codes 99202-99205 and 99211-99215. G2211 is intended to recognize the inherent complexity of office E/M visits that are the continuing focal point for all needed health care services or are part of ongoing care related to a patient’s single, serious condition or a complex condition.
But if you provide a clinically indicated office E/M service on the same date as advance care planning, you may add G2211 to the E/M code, and report 99497 or 99498.
REMOTE PHYSIOLOGIC MONITORING TIME REQUIREMENTS
What are the time requirements for reporting remote physiologic monitoring (RPM) treatment management services in 2026?
The minimum time required to report RPM services is 10 minutes. The codes are as follows:
- 99470, RPM treatment management services, clinical staff, physician, or other qualified health care professional time in calendar month requiring one real-time interactive communication with the patient/caregiver; first 10 minutes,
- 99457 — first 20 minutes,
- 99458 — each additional 20 minutes (list separately in addition to code for primary procedure).
Report one of the initial codes (99470 or 99457) based on the time spent providing RPM to manage care under a specific treatment plan.
If the time is ≥ 40 minutes, report one unit of 99457 and then 99458 for each additional full 20 minutes. You must have interactive communication with the patient at least once in each month you report RPM treatment management services.
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