What to Look for When Auditing Smoking Cessation Services
This auditing and compliance “Tip of the Week” was originally published by the National Alliance for Medical Auditing Specialists (NAMAS), a division of DoctorsManagement.
- Time must be documented: For 99406, a minimum of three minutes must be documented as time spent by the provider for the service to be billable. Time rules aren’t halved for these codes as they are for some others. Any amount of time under 3 minutes is not billable. Time between 3-10 minutes is covered by 99406 and time over 10 minutes is 99407. Time cannot be combined to use both codes on the same date.
- Frequency limits may apply:For example, Medicare covers two separate attempts to quit smoking per year, and each attempt may consist of up to four cessation counseling encounters. Consequently, the service is not payable for more than eight visits per year.
- Patient willingness to attempt to quit:The service is smoking cessation counseling and for it to be billable, the patient must express some willingness to attempt to quit, even if ultimately unsuccessful. Patients who have no interest in quitting smoking under any circumstance are not good candidates for the service.
- Documentation components:While there is no set rule for each aspect of documentation beyond the counseling time, typical documentation includes risks of continuing to smoke, benefits of not smoking and cessation strategies, including such things as cessation aides and methods, setting a date to quit, risks of returning to smoking and potential prescription drug management. All of these things don’t need to be documented, but documentation such as “discussed smoking cessation for four minutes,” is insufficient to bill these services.
- No “double dipping”:If you fail to document smoking cessation counseling time, or opt not to bill 99406-99407, medical decision making related to smoking cessation can be considered part of the E/M service. If you are billing for smoking cessation counseling, the patient’s smoking cessation should not also be considered to be part of the medical decision making of the problem focused E/M service.
- Diagnosis codes:The most common primary diagnosis code for smoking cessation is F17.200 for nicotine dependence, unspecified, uncomplicated, but look to codes between F17.200 and F17.291 for the most appropriate choice. Chronic diseases that are negatively impacted by smoking or tobacco use can be coded as secondary diagnoses.
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