π« Critical Care Coding Guide (CPT 99291, 99292)
Last Updated: September 2026
Regulatory Baseline: 2026 CMS Physician Fee Schedule (PFS) & AMA CPT Guidelines
π Executive Summary & Core Definitions
Critical care is the direct medical evaluation and management of a critically ill or critically injured patient. Unlike routine Evaluation and Management (E/M) services, critical care is exclusively time-based and is governed by strict clinical criteria and rigorous procedure time carve-out rules.
Dual Clinical Criteria for Critical Care
To report critical care services (99291, 99292), the documentation must clearly satisfy two distinct requirements:
- Critical Illness / Injury (Patient Acuity): An acute impairment of one or more vital organ systems such that there is a high probability of imminent or life-threatening deterioration in the patientβs condition (e.g., circulatory failure, acute respiratory failure, septic shock, acute renal failure requiring emergent dialysis, severe metabolic encephalopathy, active life-threatening GI bleeding).
- Critical Care Service (Physician Intervention): High-complexity Medical Decision Making (MDM) to assess, manipulate, and support vital organ system function(s) to treat vital organ system failure and/or to prevent further life-threatening deterioration. Constant active physician/QHP management and direct attention are required.
Location Independence
Critical care is service-based, not site-of-service based. It is commonly delivered in intensive care units (ICUs, CCUs, PICUs, SICUs), but it may be furnished anywhere in the hospitalβincluding the Emergency Department (ED, POS 23), Step-down/Progressive care units, Inpatient hospital floors (POS 21), Observation units (POS 22), or the Post-Anesthesia Care Unit (PACU).
β±οΈ Primary Codes & 2026 RVU Data
| CPT Code | Description | Cumulative Time on DOS | 2026 wRVU | Global Period | Assistant Fee |
|---|---|---|---|---|---|
| 99291 | Critical care, evaluation and management of the critically ill or critically injured patient; first 30β74 minutes | 30 β 74 min | ~4.50 | XXX | No |
| 99292 | Critical care, evaluation and management; each additional 30 minutes (List separately in addition to code for primary service) | Each addl 30 min (beyond 74 min) | ~2.25 | ZZZ | No |
π Critical Care Time Threshold Calculation Table
Critical care time is calculated as the cumulative total time spent by a practitioner (or practitioners within the same specialty and group) on a single calendar date.
Total Cumulative Time (Single Calendar Day)
βββ < 30 Minutes ββββββββββΊ DO NOT bill critical care! Bill appropriate E/M code
βββ 30 β 74 Minutes βββββββΊ Bill 99291 Γ 1
βββ 75 β 104 Minutes ββββββΊ Bill 99291 Γ 1 + 99292 Γ 1
βββ 105 β 134 Minutes βββββΊ Bill 99291 Γ 1 + 99292 Γ 2
βββ 135 β 164 Minutes βββββΊ Bill 99291 Γ 1 + 99292 Γ 3
βββ 165 β 194 Minutes βββββΊ Bill 99291 Γ 1 + 99292 Γ 4
βββ > 194 Minutes βββββββββΊ Add 1 unit of 99292 for each additional 30-min block (β₯15 min midpoint)
| Total Cumulative Time Spent | Primary Code | Add-on Code Units | Claim Reporting |
|---|---|---|---|
| < 30 minutes | β | β | Bill standard E/M (99222β99223, 99232β99233, or 99284β99285) |
| 30 β 74 minutes | 99291 | None | 99291 |
| 75 β 104 minutes | 99291 | 99292 Γ 1 | 99291, 99292 |
| 105 β 134 minutes | 99291 | 99292 Γ 2 | 99291, 99292 Γ 2 |
| 135 β 164 minutes | 99291 | 99292 Γ 3 | 99291, 99292 Γ 3 |
| 165 β 194 minutes | 99291 | 99292 Γ 4 | 99291, 99292 Γ 4 |
| 195 β 224 minutes | 99291 | 99292 Γ 5 | 99291, 99292 Γ 5 |
The 15-Minute Midpoint Rule for 99292
To bill the first unit of 99292, the provider must spend at least 75 minutes (which is 1 minute past the 74-minute cap of 99291, meeting the 15-minute midpoint of the first 30-minute increment: 60 + 15 = 75 min). Each subsequent unit of 99292 requires passing the 15-minute midpoint of that subsequent 30-minute block (e.g., 75 + 30 = 105 min).
β±οΈ Qualifying vs. Non-Qualifying Activities
Critical care time includes time spent directly delivering care to the patient at the bedside, as well as time spent on the unit/floor directly dedicated to that specific patientβs management.
β Billable / Countable Time
- Direct bedside examination and evaluation of the unstable patient.
- Reviewing extensive diagnostic data: Chart review, laboratory panels, blood gas analysis, electrocardiograms, imaging studies, hemodynamic monitors, and telemetry trends.
- Active unit-based discussions: Conferring with bedside intensive care nurses, respiratory therapists, clinical pharmacists, and medical/surgical consultants regarding specific treatment modifications and titration orders.
- Medical record documentation: Writing critical care orders, documenting progress notes, charting assessments, and outlining immediate intervention plans while on the unit.
- Family discussions (STRICT CRITERIA): Time spent conferring with family members or designated surrogate healthcare decision-makers ONLY IF:
- The patient is unable or incompetent to participate in decision-making (e.g., intubated, comatose, severely encephalopathic, sedated).
- The discussion is strictly necessary for obtaining medical history or determining treatment decisions/goals of care (e.g., surrogate consent, code status, advanced directives, withdrawal of life support).
- The discussion takes place on the unit or at the bedside.
β Non-Billable / Excluded Time
- Separately billable procedural services: Time spent performing procedures (e.g., intubation, central line placement) must be carved out and cannot be counted toward critical care time.
- Routine family updates: Providing emotional reassurance, bereavement counseling, general condition summaries, or answering questions when no management decisions are being made.
- Teaching and educational time: Time spent teaching residents, fellows, or medical students (unless the teaching physician is personally performing/involved in direct patient management).
- Waiting / Standby time: Time spent waiting for laboratory results, waiting for an operating room to open, or resting between clinical episodes.
- Administrative tasks: General unit management, billing paperwork, or attending multi-patient interdisciplinary administrative meetings.
- Overlapping / Simultaneous patient care: Clinicians cannot count time spent simultaneously caring for another patient.
π¦ Bundled Services vs. Separately Billable Procedures
CPT guidelines explicitly bundle specific routine intensive care diagnostic and therapeutic services into 99291 and 99292. These services cannot be reported separately on the same date by the same provider/group. However, the time spent performing them is counted toward total critical care time.
1. Services Bundled into Critical Care (Do NOT Bill Separately)
| Organ System / Category | Bundled CPT Codes | Clinical Description |
|---|---|---|
| Vascular Access | 36000, 36410, 36415, 36591, 36600 | Routine peripheral IV insertion, routine venipunctures, capillary blood collection, collection of blood from central line, routine arterial puncture. |
| Pulmonary / Respiratory | 71045, 71046, 94002β94004, 94660, 94662, 94760β94762 | Routine chest X-rays (single/2 views), ventilator management (initial/subsequent/home), CPAP/BiPAP initiation and management, continuous pulse oximetry. |
| Gastrointestinal | 43752, 43753 | Nasogastric (NG) / orogastric tube placement, gastric intubation and aspiration/lavage. |
| Cardiac / Hemodynamic | 92953, 93561, 93562 | Temporary transcutaneous pacing, indicator dilution cardiac output measurements (subsequent/initial). |
| Diagnostic Interpretation | 82800β82810, 99090 | Interpretation of arterial blood gases (ABGs), computer-stored data analysis. |
2. Separately Billable Procedures (The Procedure Time Carve-Out Rule)
Invasive bedside surgical and procedural interventions are not bundled into critical care. They may be billed separately using their distinct CPT codes.
Mandatory Procedure Time Carve-Out
When a physician performs a separately billable procedure while managing a critically ill patient, the time dedicated to performing that procedure CANNOT be counted toward critical care time.
The provider must explicitly document:
- Total critical care time.
- Total procedure time.
- Confirmation that procedure time was subtracted/carved out from the reported critical care time.
| Bedside Procedure | CPT Code | Modifier | Carve-Out Requirement |
|---|---|---|---|
| Endotracheal Intubation | 31500 | None / -59 if edit | Deduct intubation time (e.g., 15 min) from CC time |
| Central Venous Catheter Insertion (Non-tunneled) | 36556 (age 5+) / 36555 (<5) | None | Deduct line placement time (e.g., 20β30 min) |
| Arterial Line Placement (Percutaneous) | 36620 | None | Deduct A-line insertion time (e.g., 15 min) |
| Tube Thoracostomy (Chest Tube) | 32551 | None | Deduct chest tube insertion time (e.g., 25 min) |
| Cardiopulmonary Resuscitation (CPR) | 92950 | None | Deduct active CPR resuscitation time |
| Temporary Transvenous Pacemaker | 33210 | None | Deduct catheter insertion and pacing setup time |
| Ultrasound Guidance for Vascular Access | 76937 | None | Deduct imaging and vessel verification time |
| Diagnostic / Therapeutic Lumbar Puncture | 62270 | None | Deduct LP positioning, puncture, and fluid time |
| Thoracentesis / Paracentesis | 32554β32555 / 49082β49083 | None | Deduct aspiration and drainage time |
π Carve-Out Example
- Scenario: An intensivist spends 85 minutes total in the ICU managing a patient in refractory septic shock with respiratory collapse.
- Procedures Performed:
- Calculation:
- Coding:
π₯ Split/Shared Critical Care Visits (CMS 2024β2026 Rules)
Under Medicare guidelines (CMS IOM Pub. 100-04, Ch. 12, Β§30.6.18), split (or shared) critical care visits occur when a physician and a Non-Physician Practitioner (NPP / NP / PA) from the same group practice jointly furnish critical care to a patient on the same calendar date in a recognized facility setting (POS 21 Inpatient, POS 22 Outpatient/Observation, POS 23 ED).
Split/Shared Critical Care Time Calculation
βββ Physician Time: 35 mins
βββ NP/PA Time: 45 mins
βββ Combined Total: 80 mins (Supports 99291 + 99292)
βββ Billing Provider Determination:
βββ Physician (35/80 = 43.8%) βββΊ < 50% (Cannot bill under MD)
βββ NP/PA (45/80 = 56.2%) βββββββΊ > 50% βββΊ NP/PA Bills 99291-FS + 99292-FS (Paid at 85%)
Key Regulatory Rules for Split/Shared Critical Care
- Time-Only Substantive Portion: Unlike standard E/M visits where the substantive portion can be determined by MDM or time, critical care substantive portion is strictly determined by total cumulative time.
- More Than Half (> 50% Rule): The practitioner who personally performs more than 50% of the total combined critical care time is the billing practitioner.
- Modifier -FS: Must be appended to both 99291 and 99292 to identify the claim as a split/shared visit.
- No Overlapping Time: Time spent together at the bedside by both the physician and the NPP can only be counted once toward total time.
- Reimbursement:
Split/Shared Documentation Requirement
Both practitioners must document their individual involvement, individual non-overlapping times spent, and specific clinical activities. The billing practitioner must sign and date the medical record.
π Teaching Physician Guidelines (Modifier -GC)
When a teaching physician supervises a resident or fellow providing critical care, specific CMS guidelines apply:
- 100% Physical Presence Rule: The teaching physician must be personally present for the entire duration of the time billed as critical care (e.g., if 60 minutes of critical care is billed, the teaching physician must have been present for the full 60 minutes).
- Exclusion of Resident-Alone Time: Time spent by a resident alone reviewing records, examining the patient, or documenting cannot be counted toward the teaching physicianβs critical care time.
- Teaching Attestation Documentation: The teaching physician must personally document:
- Total time the teaching physician personally spent providing critical care.
- Confirmation of physical presence during that time.
- Clinical assessment of critical illness and organ failure.
- Specific management interventions and high-complexity decision-making provided.
- No Primary Care Exception: The Primary Care Exception (PCE / -GE) never applies to critical care. Modifier -GC is appended to indicate teaching physician involvement.
π Same-Day Services, Multiple Specialties, & Global Surgery
1. Same-Day Routine E/M + Critical Care (Modifier -25)
- Scenario: A hospitalist performs a morning subsequent hospital visit (99233) on a stable inpatient. Later that afternoon, the patient experiences sudden acute aspiration, septic shock, and respiratory failure, requiring 60 minutes of emergency critical care (99291).
- Billing Rule: Both services are billable.
2. Concurrent Critical Care by Multiple Specialties
- Same Specialty / Same Group: Physicians of the same specialty in the same group cannot bill separate critical care codes on the same date. Their time must be aggregated into a single claim (e.g., Partner A 30 min + Partner B 30 min = 60 min Bill
99291Γ 1). - Different Specialties: Multiple physicians of different specialties can each bill critical care on the same date provided that:
- Each physician is actively managing a distinct, non-overlapping organ system failure within their scope of expertise.
- The care is fully non-duplicative and medically necessary.
3. Critical Care During Global Surgical Periods (Modifier -FT vs. -24)
| Modifier | Payer Scope | Billing Circumstance |
|---|---|---|
| -FT | Medicare Part B | Reported on critical care codes (99291, 99292) when critical care is provided by the operating surgeon (or same group/specialty) during a global surgical period (10-day or 90-day), or on the same day as surgery, unrelated to the surgical procedure itself (e.g., patient undergoes elective hip replacement and postoperatively develops acute myocardial infarction with cardiogenic shock). |
| -24 | Commercial / Non-Medicare | Used on E/M codes to indicate unrelated E/M service during a postoperative global period. (Note: For Medicare critical care claims, CMS mandates modifier -FT instead of -24). |
| -25 | All Payers | Used when pre-operative critical care is provided on the same day as an emergency surgical procedure to stabilize the patient prior to entering the OR. |
π Auditor-Proof Critical Care Documentation Checklist
When defending critical care claims against Medicare Advantage, MAC, and commercial audit scrutiny, ensure the chart includes these seven vital elements:
- 1. Vital Organ System Failure Identified: Explicit documentation of acute life-threatening organ system dysfunction (e.g., acute respiratory distress syndrome, hemodynamic instability requiring continuous norepinephrine infusion, acute renal shutdown, severe acidosis with pH < 7.15).
- 2. High-Complexity Interventions: Documentation of active pharmacologic titration, ventilator adjustments, fluid resuscitation, and continuous hemodynamic monitoring.
- 3. Exact Cumulative Time Documented: Total critical care time stated explicitly in minutes (e.g., βTotal critical care time spent: 65 minutesβ). Avoid ambiguous statements like βSpent over an hour on the unit.β
- 4. Explicit Carve-Out Statement: βTotal time excludes time spent performing separately billable procedures (intubation and central line placement).β
- 5. Family Meeting Criteria Met (if time included): Documentation clearly specifies patient lacked capacity, discussion focused strictly on surrogate treatment decisions / code status, and family members were identified.
- 6. Split/Shared Specifics (if applicable): Separate entries by MD and NP detailing individual non-overlapping times and clinical activities, with modifier -FS appended by the majority-time clinician.
- 7. Teaching Physician Physical Presence (if applicable): Attestation confirming 100% direct physical presence for the full duration of billed critical care time with modifier -GC.
π Related Vault Resources
- 00 Inpatient ProFee Coding MOC β Inpatient ProFee Master Map of Content
- 01 Inpatient ProFee Overview β Foundational ProFee Guidelines
- Inpatient E&M Codes β Hospital Inpatient & Observation E/M Services
- FS β Split-Shared Visits β Comprehensive Split/Shared Billing Rules & Modifier -FS
- GC β Teaching Physician Rules β Teaching Physician Regulations & Supervision Levels
- Modifier -25 vs -57 β Modifier 25 & 57 Decision Hierarchy
- Inpatient Modifiers β Master Modifier Reference for Inpatient Professional Claims
- Prolonged Services β Non-Critical Care Prolonged Services (99418 vs. G0316)
- CMS Medicare Guidelines for Inpatient β CMS Payment Policies and Regulations
- CPT Assistant References for Inpatient β CPT Assistant Precedents & Audit Defense
- Primary Codes: 99291, 99292
- Bedside Procedures: 31500 (Intubation), 36556 (Central Line), 36620 (A-Line), 32551 (Chest Tube), 92950 (CPR)
- Key Modifiers: -25, -FT, -FS, -GC, -59, -AI