First impressions can be deceiving. The descriptor for modifier FT is a prime example.
In the final 2022 physician fee schedule (PFS) released Nov. 2, CMS announced it would create a new modifier for critical care services (
99291-99292) that occur during an unrelated procedure’s global surgical period. The agency
released the modifier and descriptor a few days later. However, the descriptor appears to have a broader scope than that which CMS discussed in the fee schedule:
Unrelated evaluation and management (E/M) visit during a postoperative period, or on the same day as a procedure or another E/M visit. Report when an E/M visit is furnished within the global period but is unrelated, or when one or more additional E/M visits furnished on the same day are unrelated.
Do the references to same-day E/M visits mean that the modifier should be used when a provider bills a critical care visit and another E/M visit for the same patient on the same day?
No, they do not, CMS says.
“As discussed in our CY 2022 PFS final rule, the modifier should be included on a claim in circumstances when critical care services are performed during the global surgical period of an unrelated procedure,” a CMS spokesperson explained in response to a question from Part B News.
The "on the same day as a procedure or another E/M visit" portion of the descriptor does not have a practical application.
The statement from CMS included a reminder that it created the modifier as part of an ongoing effort to keep tabs on billing patterns and to rein in costs.
“CMS continues to review its longstanding policies to identify billing scenarios when payment should reflect efficiencies that result
from an overlap in furnished services. CMS created the FT modifier to inform this objective,” the CMS spokesperson said.
The spokesperson also suggested more guidance on the modifier could be on the horizon: “CMS will likely release educational materials to clarify this new policy soon.”