Q&A: Can we bill for pronouncing time of death?

Q: Our group covers several nursing homes, and we are called upon to pronounce death. We have never billed to do so, even though we travel to the nursing home-sometimes in the middle of the night-to examine the patient. Is it possible to bill for this service, and if so, how do we go about it?

A: The following is from Medicare's Evaluation/Management Guide: "Pronouncement of Death: According to established legal principles, an individual is not considered deceased until there has been official pronouncement of death. An individual is therefore considered to have expired as of the time he/she is pronounced dead by a person who is legally authorized to make such a pronouncement, usually a physician. Reasonable and necessary medical services rendered up to and including pronouncement of death by a physician are covered as diagnostic or therapeutic services." In essence, you may bill for the services you provide. Watch the date of service if your services are rendered overnight. If you pronounce the patient dead at 11:59 p.m. on the 12th, but use the 13th to bill your service, you will not be reimbursed, since the service occurred after the date of death.