With the ongoing increase in available wound care products and services, this author discusses how to approach coding for these complex cases.
Wound care is a large part of many podiatry practices today. There has been an explosion of wound care products and techniques that we may utilize in trying to treat the stubborn wounds we deal with on a day-to-day basis. Unfortunately, with the increased volume and cost of these items comes increased scrutiny of how and when we use these products and services. It is important to understand the most common aspects of billing and coding for wound care in order to succeed for both your practice and your patients.
Wounds can be very complicated with frequent and ongoing reevaluation of treatment outcomes. Some wounds go on to heal with simple measures and we are primarily monitoring progress until healing is eventually complete. These two scenarios differ from one another when considering proper coding. When billing an evaluation and management service (E&M) at the same encounter for which you are billing a procedure (such as debridement), there must be a significant and separately identifiable E&M service from the procedure in order to be paid for both services. This would require taking a history, performing an examination and then eventual decision-making. These three key components are the basis for an E&M service.
Remember that for a follow-up E&M service to be eligible for payment, you must document two of the three E&M components as being significant and separately identifiable. Also, for every procedure, there is an “E&M” portion built into the allowed fee. In this instance, one must document and show that there is more history, examination and decision making than would be included in the fee allowance for the procedure.
For example, a patient presents to your office with a new wound. You obtain a history of the wound, examine the wound and then decide what treatment to pursue. You also perform an in-office debridement. As a result, at this initial presentation of the wound an E&M service would be appropriate in addition to the procedure. The level of E&M service billed would NOT necessarily be based solely upon the complexity of the wound (e.g. exposed bone) but rather the level of each key component performed and the resulting level of documentation in your chart. As always, charting is key.
The patient then returns the next week for a follow-up visit. If there are no significant history or examination changes from the previous visit and the wound is progressing as expected, then there may not be an eligible E&M service separate from any procedure that one may also perform on that day. However, if at a subsequent visit, the physician needs to alter the wound care protocol (if the wound is deteriorating and additional imaging is necessary, or one needs to initiate or change antibiotic therapy), then an E&M service would be appropriate to bill based upon your level of documentation. The chart notes would need to document the changes that occurred since the last encounter and the associated decision-making.
Benefits And Pitfalls Of EHRs In E&M Documentation
With many office EHRs, there is the ability to bring information forward from previous patient encounters. This can be deemed templating or cloning of charts, but this is a double-edged sword. EHR-associated templating can make our lives easier when it comes to documentation and completeness of a chart note. However, you cannot use patient data or information brought forward from a previous chart note to augment your current chart note just to bill an E&M service, or a higher level of service.
Simply cutting and pasting the history from week to week does not meet proper documentation requirements. You would only get “credit” for any history that has changed since the last encounter. Similarly, if the examination is unchanged except for the fact the wound is getting smaller and progressing as expected, then there is no real “credit” there either. Lastly if your decision making is essentially to “continue with current treatment course,” there is no added consideration there as well. Without documentation of changes in history, additional examination or decision making (at least two of three components), there is no additional E&M service to bill. Lastly, be very careful with templates as one may inadvertently bring charting errors forward as well that can make your chart look poor and clearly templated.
Key Concepts In Coding For Wound Debridement
Debridement is a common part of the treatment algorithm for wounds. There are two debridement code series, Current Procedural Terminology (CPT) 9759X and 1104X, that clinicians can utilize. CPT series 9759X involves selective debridement of epidermal and dermal tissue, and superficial biofilm. CPT series 1104X involves the excisional debridement of deeper tissue including subcutaneous tissue, muscle, tendon or bone. One also needs to clearly identify the type of tissue he or she has debrided in the chart notes.
In addition, proper documentation should include the location of the wound, the size of the wound, the instruments one uses for debridement, if anesthesia is required and the type and anatomic depth of debridement. Additionally, examination documentation should include the condition and characteristics of the wound bed as well as notation on any drainage, odor or cellulitis.
We often see multiple wounds on the feet and selection of the appropriate code is based upon the aggregate size of similar wounds, not on a right foot or left foot basis. Remember that wound codes are not foot specific. They apply to the entire body. Accordingly, one determines the codes based on the tissue type debrided and these codes are applicable to any body part. Therefore, add up all similar wounds of similar debridement depths and combine them into one code per the appropriate aggregate sizing.
If there are three wounds on a foot, two of which require debridement to subcutaneous tissue and a third wound requires only dermal debridement, the proper coding would be CPT 11042 (debridement of subcutaneous tissue) for the composite two wounds requiring subcutaneous tissue debridement and CPT 97597 (debridement of non-viable tissue) for the third wound, which requires only more superficial selective debridement. Do not use right or left foot modifiers as those are incorrect and will result in your claim being denied. A -59 modifier is necessary to be paid for both debridement codes when you bill them on the same day.
These wound care codes are listed per 20 sq cm. If the aggregate size of similar wounds exceeds that amount, there are add-on codes that clinicians can bill. Accordingly, for the debridement of an aggregate 60 sq cm wound through subcutaneous tissue, CPT 11042 applies for the first 20 sq cm and CPT 11045 (two units in this case) applies for each additional 20 sq cm.
Correct measurement of wounds is important not only to document the presence or absence of improvement, but also to properly select the appropriate CPT debridement code. A wound may be 4 cm in overall diameter but the base of the wound, which has the subcutaneous tissue you are debriding, is only 2 cm in diameter. Billing is based upon the deepest tissue debrided and the amount of that specific tissue in square centimeters. In this scenario, one is debriding two sq cm. Keep in mind that if the wound extends deep to bone but you only debride subcutaneous tissue, the proper billing level would be CPT 11042 (debridement subcutaneous tissue), not CPT 11044 (debridement of bone).
When applying skin substitutes, one needs to perform some basic wound preparation/care prior to the application of the product. This wound preparation may include some tissue debridement. CPT 15271 is used for application of the product on the leg and CPT 15275 for the foot. You cannot bill both CPT series 1527X in combination with either CPT 9759X/1104X series codes as this would be essentially duplicate billing. You can only bill for the wound preparation codes when applying a wound care product. CPT 15271 for application of the product on the leg and CPT 15275 for the foot are designated in 25 sq cm increments. The add-on codes are CPT 15272 (for the leg) and CPT 15276 (for the foot) are used for aggregate wounds greater than 25 sq cm and billed per each 25 sq cm increment. If the wounds were to exceed aggregate 100 sq cm in size, CPT 15273/15274 and CPT 15277/15278 codes are to be used as a single code (i.e you cannot bill CPT 15277 in addition to 15275 and 15276, but these should be rare in the foot and ankle).
Choosing Proper Coding For Skin Substitute Products
The next issue is selection of a skin substitute product. Many products have specific FDA indications. Some are only indicated for diabetic foot wounds or venous leg ulcers. Reimbursement for the use of these products is limited to those indications. If the patient has an ulcer but is not diabetic, some wound care products may not be approved if the indication is only for a diabetic foot wound. Not all products are indicated for exposed bone or tendon, either. Some insurance companies have additional requirements. One example may be in regard to the coverage or lack thereof for small wounds. There may be a minimum one cm diameter wound size requirement, which clinicians need to be aware of. Additionally, some insurances have limitations on the number of times a clinician can use a product without additional authorization.
Each skin substitute product has a specific Q code, which identifies the product. Make sure the product you use is properly identified. Exercise caution if a manufacturer representative tells you to bill his or her company’s product using a certain Q code just because it is “similar” to some other product.
Therefore, when dealing with private insurance carriers, it is important to pre-authorize every wound care product. This applies to both primary as well as any secondary insurance carriers. These products are very expensive and if the product is not allowed for any reason then the facility, provider or patient will be billed in full for the product.
Many patients today have insurance plans with very high deductibles so even though the use of skin substitute and other advance wound care products maybe a covered benefit they may or may not be affordable. Even a 20 percent co-insurance may be out of reach for some patients. Keep this in mind when selecting products for your patient. One may need to make compromises when selecting products based, unfortunately, on financial concerns. In addition to any medical indications, the place of service may also be an issue. Some products are only reimbursable when the application is in an operating room setting versus a private office or wound care center.
The next question is when to start using skin substitutes. That obviously depends on the quality of the base of wound. This documentation is also necessary from a medicolegal aspect as well. If the wound bed is poor, one first needs to perform proper debridement and wound preparation. If there is significant venous insufficiency and edema, physicians need to address that promptly. Other things to consider are addressing out of control hemoglobin A1c levels and overall vascular status. Superficial or systemic infections warrant primary treatment as well. There also needs to be proper offloading. If one does not address these factors, these products, although very effective, can be significantly hindered in their ability to heal wounds. If the insurance carrier only allows five product applications, then using the product on an improperly prepared wound bed would be wasteful and detrimental to the patient.
Many insurance carriers require some level of more conservative care before initiating the start of skin substitutes or other advanced wound care products. This is obviously controversial. The current standard in wound healing is 50 percent closure of the wound in four weeks. One could make the argument of starting wound care products, such as skin substitutes, as quickly as possible for patients who have high morbidity issues. However, many carriers may want at least four to six weeks of conservative treatment that could include documentation of offloading, local debridement, compression and addressing infectious or metabolic issues. Documentation of wound size and quality is very important in these cases.
If one institutes conservative wound care measures and the wound is showing steady progress with these measures alone, then the question becomes “Should a skin substitute be used at all?” This is an area of discussion right now with various Medicare carriers. If the wound is going to heal on its own based upon addressing factors such as glucose levels, infection, offloading, and compression, then it may very well heal without applying skin substitutes. There needs to be documentation of why, if a wound is healing on its own in a reasonably steady fashion, skin substitutes are required. This is a current area of audit and Medicare scrutiny. If the wound healing has stalled or is progressing very slowly, then proper documentation of this may result in authorization from the insurance carrier and also protect you in the case of an audit.
I personally recommend making patients aware of insurance company regulations and restrictions so they can also help advocate for themselves. This can be helpful when dealing with the insurance company to get authorization for wound care services and products.
Navigating Off-Label Uses For Wound Care Products
There have been many recent audits surrounding wound care products. Many of these audits are related to not using the proper product for the proper type of wound. Newer audits are for non-wound-related uses of skin substitutes. Many products, imaging systems that are commonplace now were at one point off-label. If you are using a skin substitute for an off-label use, make sure you and/or your staff are very clear about the product you are using, and how you will use it when obtaining a pre-authorization.
Physicians are using wound care products in non-wound-related foot surgery to augment tendon repairs and act as an interface between tissue layers to limit adhesions and/or scarring. Unfortunately, I have seen requests for the use of these products in simple hammertoe repairs and even matrixectomies! Be able to prove some level of medical basis for the off-label use of these products in an appeal situation. A surgeon’s personal preference/past experience is not enough.
Also be careful when interacting with manufacturer representatives who may imply proper use of these products in situations that may indeed be inappropriate. This may get you flagged for an audit. Make sure you document the off-label use of the product and that you informed the patient you were using the product off-label. You should have the patient sign a form similar to an ABN stating that he or she acknowledges the off-label use of the product, agrees to pay for the product and that the insurance company will not be billed for it
Wound care has been an integral part of the podiatric profession for quite some time. This field and its available treatment options has exploded over the past few years. It can be a very professionally rewarding part of your practice. In order to best succeed in the treatment of wounds, make sure you and your staff are well versed in treatment options, product availability, indications and proper billing protocols.
Dr. Poggio is a California Podiatric Medicine Association Liaison to Noridian JE MAC and a medical consultant to several national health insurance and review organizations. He is a member of the American College of Podiatric Medical Reviewers and is board-certified by the American Board of Podiatric Medicine and the American Board of Podiatric Orthopedics and Primary Podiatric Medicine.