Primary Care Coding Alert
Know If HRA Should be Separately Billed With E/M
Question: A patient of one of our providers came in for an annual wellness visit and the physician had the patient fill out a health risk assessment (HRA). There was no abnormality or preexisting problem found during the visit. She wants to bill for the patient discussion about the HRA. How should I code this? Is a modifier needed?
Ohio Subscriber
Answer: You won’t need a modifier but you need to consult with your payers on whether they allow you to bill the HRA service separate from the E/M or other code used to report the annual wellness visit. Some payers do not consider a health risk assessment instrument (99420, Administration and interpretation of health risk assessment instrument [e.g., health hazard appraisal]) separately reimbursable, but rather incidental to the associated E/M services. For instance, the Centers for Medicare & Medicaid Services considers an HRA to be an inherent part of the Medicare Annual Wellness Visit. In fact, the information gleaned from the HRA can be used toward the history components of the E/M service and possibly in some of the medical decision-making, if otherwise using an E/M code to report the visit.
For documentation purposes, save the HRA in the patient’s chart. You also need to clearly illustrate the discussion about the assessment in the patient’s record.
Background: According to the Affordable Care Act (ACA), “As part of the annual wellness visit, an health risk assessment (HRA) may be completed before, or as part of, a visit with a health professional who may be a physician, physician’s assistant, nurse practitioner, or clinical nurse specialist, or a team of such medical professionals working under the direction supervision of a physician.”
Section 4103 of the ACA specifies that the Secretary of Health and Human Services will develop guidelines to provide that HRAs:
1. Identify chronic diseases, injury risks, modifiable risk factors, and urgent health needs of an individual
2. May be furnished through an interactive telephonic or web-based program
3. May be offered during the encounter with a healthcare professional or through community-based prevention programs
4. May be provided through any other means the secretary determines appropriate to maximize accessibility and ease of use by beneficiaries, while ensuring the privacy of beneficiaries.
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