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Family Practice Coding Alert


Death Pronouncement Involves Face-to-Face Work

Question: A nursing facility calls a family physician because a patient has died. The physician pronounces the patient dead and completes all necessary paper work. Should I charge for the FP's services, and if so, which codes should I report?

North Dakota Subscriber
Answer: You should report the service with the appropriate subsequent nursing facility care code (99311-99313, Subsequent nursing facility care, per day, for the evaluation and management of a new or established patient ...) or nursing facility discharge code (99315-99316, Nursing facility discharge day management ...). Choose the code that best describes the physician's services.

Bust this myth: Don't assume that because Medicare covers only face-to-face encounters, you shouldn't charge death pronouncement services. An individual is not considered dead until a legal authority, usually a physician, pronounces the patient dead, according to CMS. Thus, the examination that leads to the patient's pronouncement involves a face-to-face covered encounter. (Medicare's explanation appears in CMS Manual System, Pub 100-3, Medicare National Coverage Determinations Manual, Chapter 1, Section 70.4, available online at

Problem: CPT does not include a code for death pronouncement. Therefore, you should use the code that best describes the services the FP renders to the patient during the pronouncement of death. Check with your carrier for details.For instance, Noridian (Medicare Part B for 11 Western states) recommends using nursing facility discharge codes (99315-99316) "if the primary service provided is the pronouncement of death, completion of the death summary and discussion with the deceased patient's family."

CPT Assistant (November 2002) also advises coding pronouncement of death using 99315 or 99316. The alternative is to bill subsequent care codes (99311-99313), if the FP renders services that "are necessary and reasonable at the level claimed and supported by medical record documentation that satisfies applicable E/M documentation guidelines."

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