E/M Level 4 visit for ordering injection?« Back to Questions List

I was wondering your thoughts on E/M billing coding when an epidural injection/MBB/RFA/etc is ordered. We recently used an external audit service to ensure our coding was up to snuff and they felt that any procedure that doesn’t have a global period greater than 10 days should be considered minor and thus “low risk” for medical decision making and thus a level 3 visit. We feel that an injection over the spinal cord, nerve, or destruction of nerve etc conveys at least moderate risk as a risk benefit discussion takes place where adverse outcomes of these procedures could include nerve injury, paralysis, adverse reaction to medication, or infection, and thus should be a level 4 visit. Just advising a patient to trial over the counter medications incurs enough risk to be a level 3 visit, clearly discussing and ordering an injection should be greater risk than telling a patient to try ibuprofen. What are your thoughts?