ED FACILITY BILLING

We are billing both professional & facility charges for our Emergency Room. My question is about critical care. It is our understanding that critical care in the facility has to be face to face & can't be the same time as the provider. Are we interpreting this from CMS Manual correctly?

"Under the OPPS, the time that can be reported as critical care is the time spent by a physician and/or hospital staff engaged in active face to face critical care of a critically ill or injured patient. If physician and hospital staff are simultaneously engaged in this active face to face care, the time involved can only be counted once."

Thanks in advance!
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