Q: A sales rep has suggested we offer 21-day continuous auto-trigger event monitoring, using a device that transmits over a wireless network. The company plans to bill insurance directly for the technical component using CPT 93236. It further suggests that we can bill for the professional component, CPT 93237, and bill for 21 units (billed for each day the patient is compliant with wearing the device).

Virginia martin, CPC, CHBC

A: The type of monitoring device affects the selection of the CPT codes used to report the service. CPT defines Mobile Cardiovascular Telemetry as "continuous recording of electrocardiographic rhythm from external electrodes placed on the patient's body." Segments are automatically transmitted to a remote surveillance location continuously attended by a technician who reviews the data and notifies the physician depending upon prescribed criteria. This section recommends utilizing codes 93224-93272 (for 24-hour monitoring) and 93228-93229 (for once every 30 days) to report these services. Code 93235 (the base code for 93236 and 93237) indicates 24-hour monitoring, and the parenthetical notes immediately following the indented portion of that code subset indicate "For wearable mobile telemetry with ECG triggered transmissions to an attended surveillance center see 93228, 93229." The definition of 93228 is "Wearable mobile cardiovascular telemetry with electrocardiographic recording, concurrent computerized real-time data analysis and greater than 24 hours of accessible ECG data storage (retrievable with query) with ECG-triggered and patient-selected events transmitted to a remote attended surveillance center for up to 30 days; physician review and interpretation with report." The parenthetical notes following that code indicate that it should not be reported more than once in a 30-day period.

CPT instructions for a patient who will wear a monitoring device linked to an attended surveillance center for more than a 24-hour period indicate to use one of the codes provided for 30-day attendance and bill only once during that period. Of course, medical necessity should drive the decision to monitor a patient for more than 24 hours.

We suggest having the medical equipment supplier obtain an opinion letter from your Medicare carrier describing the suggested arrangement, including the CPT codes being recommended. If the opinion letter is positive, go ahead with the arrangement. There is too much potential liability for any medical practitioner today; an arrangement with a vendor in which the practitioner could be put at risk for fraud and abuse simply does not make sense.

The author, vice president of operations for Reed Medical Systems in Monroe, Michigan, has more than 30 years of experience as a practice management consultant, and is also a certified coding specialist, certified compliance officer, and a certified medical assistant.