Cancer patients always High Risk??

Our Radiation/Oncology physicians are wanting to code 99205's & 99215's based on their idea that "all cancer patients are high risk". We believe they are using the MDM guideline of "Illness with threat to life or bodily function. We are having a hard time understanding how a patient that has been staged a Level 1 could be the same risk as a patient staged at a Level 4 or 5. Is there any guidelines that could help assist with clarification related to risk for cancer patients?

re: Cancer patients always High Risk??

When you look at the other elements of high risk in the Marshfield tool (or others), their definition doesn't really hold sway. By that context, you could document a COPD patient as always high risk.

Here are the examples listed for acute or chronic illnesses or injuries that may pose a threat to life or bodily function:
"multiple trauma, acute MI, pulmonary embolus, severe respiratory distress, progressive severe rheumatoid arthritis, psychiatric illness with potential threat to self or others, perionitis, acute renal failure."

Even chronic renal failure isn't listed because it is a more gradual loss of kidney function. I would approach cancer the same way.

If it is a gradually worsening condition, or one that is responding to treatment favorably, then I wouldn't credit a 5. I'd definitely not do it routinely. On other other hand, if the patient has a severe exacerbation or the cancer is being diagnosed and a treatment plan formulated (as in a new patient encounter), then you might get to high MDM.

All of this assumes you are relying on your medical necessity to drive coding, not your comprehensive history/exam.