CMS personnel participating in the November 22, 2011 Hospital Open Door Forum stated that a hospital may not bill Medicare for a low-level emergency department visit in instances where a patient receives only triage services from an ED nurse and elopes before being seen by a physician. Providers may bill Medicare for any diagnostic services furnished to the patient and also may bill the patient for the triage visit as a noncovered service for which the patient is liable.
CMS personnel made clear that an ED visit is only billable if the patient is actually seen by a physician. Triage performed pursuant to a standing ED physician order is not billable if the patient does not see a physician. CMS personnel also rejected a questioner's suggestion that a hospital could bill for the visit if the triage nurse conferred with a physician regarding the patient's condition before the patient eloped. The key consideration, the participants stated, was whether the patient actually met with the physician.
CMS will post an FAQ to its Web site on this issue by the next Open Door Forum, scheduled for January 2012.