On Sept. 24, the American Hospital Association sent a letter to Kathleen Sebelius, Secretary of Health and Human Services, and to Attorney General Eric Holder, urging HHS to work with the hospital association to quickly develop national guidelines for the coding of emergency department and medical clinic visits, in response to public attention on the issue of potentially abuse coding in that area, as highlighted by a recent New York Times investigative report on the topic. (See also Mark Hagland’s blog about the New York Times article.)

Essentially challenging any contention that potentially abusive coding that leverages automated capabilities within EHRs is the fault of physicians or hospitals, Rich Umbdenstock, the president and CEO of the hospital association, with offices in Washington, D.C. and Chicago, wrote in the letter to Sebelius and Holder that, “In the 2004 and 2005 OPPS [Outpatient Prospective Payment System] rules, CMS [the federal Centers for Medicare & Medicaid Services] stated it would consider national coding guidelines recommended by panel. However, to date,” Umbdenstock charged, “CMS has not established national E/M guidelines.” In addition, Umbdenstock wrote, “The AHA has long called for national guidelines for hospital ED and clinic visits, and we stand ready to work with CMS in the development and vetting of such guidelines. Once national guidelines are developed” he added, “we recommend that a formal proposal be presented to the AMA’s CPT Editorial Panel to create unique CPT codes for hospital reporting of ED and clinic visits based on the national guidelines. These codes then could be widely reported by hospitals to all payers.”