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Conscious Sedation Guidelines in Surgery Centers: Thoughts From Tamara Wagner and Diana Hilliard of National Medical Billing Services

This article was written by Tamara Wagner, BS, CPC, Vice President of Coding and Diana Hilliard, JD, Manager Managed Care Contracts for National Medical Billing Services.

The AMA recently issued an opinion that all procedures whose description involves time (i.e. 99144: conscious sedation for the first 30 minutes intra-service time) must have an intra-service duration of more than 50 percent of the time interval to be billed. Therefore, conscious sedation for the first 30 minutes must span at least 16 minutes to be billed. Likewise, code 99145, conscious sedation for each additional 15 minutes, must have an intra-service time of at least eight minutes to be billed. You will need documentation of the conscious sedation (start and stop time) in order to bill for this service.

Intra-service time refers to the time actually spent providing the service, as opposed to pre-time, preparing to start or post time, after the procedure is complete.  Conscious sedation includes the assessment of the patient's fitness to receive sedative medications; establishment of IV access and delivery of fluids to maintain IV patency; administration of sedating agent(s); maintenance of the desired level of sedation during the procedure; monitoring of oxygen saturation, heart rate and BP; and overseeing the patient's recovery from the sedative agents. Intra-service time starts with the administration of the sedation agent(s), requires face-to-face attendance by the physician providing the service, and ends when the physician leaves the patient's presence. Intra-service time does not include pre-service patient assessment and oversight of the recovery phase. Since both the selection of the correct codes (described below) and number of times that one may report these codes depend on the intra-service time, understanding this definition is extremely important.

When reporting conscious sedation with codes 99143-99150, it bears repeating that Intra-service time begins with the administration of sedation, requires continuous face-to-face attendance, and concludes when personal contact with the physician providing the sedation ends. This definition parallels the definition of anesthesia time found in the "Anesthesia Guidelines" section of CPT.

CPT defines pre-procedure patient assessment; establishment and maintenance of IV access; administration of agents and IV fluids; maintenance of sedation; monitoring of BP, heart rate, and oxygen saturation (CPT codes 94760-94762); and recovery as integral components of the Conscious Sedation codes 99143-99150. One should not separately list any of these integral services when submitting claims for moderate sedation care.

In order for your practice to be in compliance, it is very important that the intra-service (face-to-face) time is documented clearly, accurately and consistently.

Learn more about National Medical Billing Services.

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