Q&A: Billing E/M services for LWBS patients

Q: Are we allowed to bill the facility evaluation and management (E/M) service if a patient was triaged then left without being seen (LWBS) by a physician/nonphysician practitioner?

A: Simply put, no. CMS indicated that hospital outpatient therapeutic services and supplies (including visits) must be furnished incident to a physician's service and under the order of a physician or other qualified practitioner. Services provided by a nurse in response to a standing order do not satisfy this requirement. See the January 2012 update of the hospital Outpatient Prospective Payment System. The pertinent information starts at the bottom of page eight. Remember, this is a condition of payment, not a condition of participation.

Editor’s note: This question was answered by NAHRI Advisory Board member Christian S. Gabriel, national director of revenue integrity at CommonSpirit Health, a newly formed by the alignment between Catholic Health Initiatives (CHI) and Dignity Health, in Dublin, California.