New CMS Rules for Prolonged Services

By Jana Weis, Gill Compliance Solutions

As part of the 2023 changes, prolonged rules have expanded to include events spanning over multiple days for certain inpatient and outpatient evaluation and management (E/M) codes. Yet, CMS also published a threshold table (below) that was not consistent with the incremental time outlined in the new G series of prolonged HCPCS codes. For example, the G0316 definition states that this code can be used for each 15 minute increment over the highest base code (applicable to 99223, 99233, or 99236). Yet, for code 99223, initial hospital, the threshold table states at least 105 minutes must be met for 99223, which has a base code time of 75 minutes. Based on the CMS definition, the CMS prolonged code should be billable after the 91^st minute.

• G0316 – Prolonged hospital inpatient or observation care evaluation and management service(s) beyond the total time for the primary service (when the primary service has been selected using time on the date of the primary service); each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact
• List separately in addition to CPT codes 99223, 99233, and 99236 for hospital inpatient or observation care evaluation and management services
• Do not report G0316 on the same date of service as other prolonged services for evaluation and management 99358, 99359, 993X0
• Do not report G0316 for any time unit less than 15 minutes  

Until the CMS manuals are officially updated, we highly recommend following the CMS threshold times to decide when you should bill for prolonged services. For example, if you are billing the initial inpatient/observation series on a Medicare patient in 2023, HCPCS code G0316 should be reported with code 99223 once you have reached a time of 105 minutes. The time for this code should only be counted on the date of the visit. In contrast, if billing a home/resident service (99350), you can count time three days before the visit, date of visit, and seven days after, as long as 110 minutes have been initially met. CMS will not cap frequency limitations for 2023 for the prolonged series.  

Family Medicine Residency of Idaho - Nampa (Educational Faculty - Family Medicine Physician)

Opportunity for an Educational Faculty member at our Family Medicine Residency program in Nampa!

The Role – Combination of Inpatient / Outpatient; 3 half-days Clinic, 3 half-days Precepting and 2 half-days Admin time per week. Average of 1 Call Night/ week at Nampa St. Luke's. Work 4 days/ week, including Call.

Who We Are – At Full Circle Health, our vision is that every Idaho community is healthy and thriving through our commitment to outstanding care and the education of tomorrow's healthcare leaders.

Our Guiding Principles - We lead with accessibility, education and compassion on a quest for better. Better health care, better communities, better lives for the people of Idaho.

• Open Doors: We welcome all members of the community emphasizing access to care for those with limit choices.
• Open Minds: As a Teaching Health Center, we focus on creating an environment of inclusion and learning through our multiple Residency and Fellowship programs across the Treasure Valley.
• Open Hearts: Compassionate care is at our core!

Benefit Information - We offer a well-rounded benefits package including everything you need.

Education

• MD or DO

Licensure/ Certification

• Must have the ability to be fully credentialed, licensed and privileged;
• Unrestricted Idaho license;
• Maintain Board certification via ABFM;
• Unrestricted Board of Pharmacy and DEA registration and all necessary federal narcotics and controlled substance numbers and licenses;
• Eligible to participate in Medicare, Medicaid and third-party payors that contract with Full Circle Health.

Other

• Our organization is a tobacco-free workplace.
• We require immunizations for all staff including COVID-19 vaccine and annual influenza vaccine as a requisite for employment. Newly hired staff who are not able to be vaccinated due to medical reasons or sincerely held religious beliefs must apply for vaccination exemption prior to employment

For more information please email hr@fullcircleidaho.org

Full Circle Health - Nampa Clinic 

(Clinical Faculty - Family Medicine Physician)

Opportunity for a Clinical Faculty member at our growing Family Medicine clinic in northern Nampa!

The Role - Outpatient only, combination of 6 half-days Clinic, 1 half-day Admin time and 1 half-day Attending per week. Work 4 days per week; Clinic from 8:30am – 5:00pm, Monday - Friday. 

Who We Are – At Full Circle Health, our vision is that every Idaho community is healthy and thriving through our commitment to outstanding care and the education of tomorrow's healthcare leaders.

Our Guiding Principles - We lead with accessibility, education and compassion on a quest for better. Better health care, better communities, better lives for the people of Idaho.

• Open Doors: We welcome all members of the community emphasizing access to care for those with limit choices.
• Open Minds: As a Teaching Health Center, we focus on creating an environment of inclusion and learning through our multiple Residency and Fellowship programs across the Treasure Valley.
• Open Hearts: Compassionate care is at our core!

Benefit Information - We offer a well-rounded benefits package including everything you need.

Education

• MD or DO

Licensure/ Certification

• Must have the ability to be fully credentialed, licensed and privileged;
• Unrestricted Idaho license;
• Maintain Board certification via ABFM;
• Unrestricted Board of Pharmacy and DEA registration and all necessary federal narcotics and controlled substance numbers and licenses;
• Eligible to participate in Medicare, Medicaid and third-party payors that contract with Full Circle Health.

Other

• Our organization is a tobacco-free workplace.
• We require immunizations for all staff including COVID-19 vaccine and annual influenza vaccine as a requisite for employment. Newly hired staff who are not able to be vaccinated due to medical reasons or sincerely held religious beliefs must apply for vaccination exemption prior to employment

For more information please email hr@fullcircleidaho.org

Idaho State University Department of Family Medicine 

(Family Medicine OB - Active Physician)

The Idaho State University Department of Family Medicine (ISU DFM) in Pocatello, Idaho, is growing. Therefore, another full-time, board-certified, broad-spectrum, OB-active family physician is being sought to join its creative, productive, collegial, multidisciplinary faculty. The ISU DFM is composed of: a well-established base family medicine residency; two new rural training tracks; a new psychiatry residency in collaboration with the University of Utah; a hospitalist fellowship; wilderness medicine fellowship; pharmacotherapy residency; psychology internship; advanced surgical obstetrics training track; clinical research center and outpatient practice in an FQHC. All components are oriented to preparing learners for rural and underserved practice. 

For more information, please contact Greg Harding at gregharding@isu.edu.