Jugna Shah, MPH, and Valerie A. Rinkle, MPA, review new comprehensive APCs (C-APC) CMS added in the 2016 OPPS final rule as well as the negative payment update due to a CMS overestimation in 2014.
Before the new year begins, Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, CDIP, COBGC, recommends taking a look at post-implementation risks CMS and third-party payers have identified. She also offers solutions on auditing and reviewing these risks. Note: To access this free article, make sure you first register here if you do not have a paid subscription. Once you have set up your free registration, you can log in and access this article by clicking here.
Providers will only have to report one data collection modifier related to a C-APC in 2016. Jugna Shah, MPH, and Valerie A. Rinkle MPA, examine the requirements behind the modifier and how APCs will also be restructured next year.
Nearly half a million patients receive dialysis services each year. Shelley C. Safian, PhD, RHIA, CCS-P, COC, CPC-I, writes about the ICD-10-CM and CPT® codes providers will need to know in order to report these services accurately.
In addition to updating procedures for 2-midnight rule reviews, the 2016 OPPS final rule includes new guidance on coding and billing issues, including reporting certain CT scan services. Jugna Shah, MPH, examines the changes and what providers need to do before 2016.
CMS is introducing multiple new modifiers that providers may need to report beginning January 1, 2016. Jugna Shah, MPH, reviews the modifiers and the conditions for reporting them.
Providers need to be careful when reporting multiple services with status indicator J1 on the same claim, as NCCI logic could result in no payment for any of the reported comprehensive APC (C-APC) services. Typically, when multiple J1 procedures or services appear on the same claim, the procedure with the highest rank according to CMS is assigned to the C-APC. Certain code combinations of J1 services will also lead to a complexity adjustment to a higher-paying C-APC.
Provider-based clinics and departments are increasingly common, but the rules for provider-based billing can often be confusing, especially given recent changes to modifiers and place of service codes.
CMS and Medicare Administrative Contractors are aware of certain issues regarding National Coverage Determinations and Local Coverage Determinations related to ICD-10 and working to resolve them as soon as possible, according to CMS.
Jugna Shah, MPH, and Valerie A. Rinkle, MPA, review newpolicies and regulations from CMS in the 2016 OPPS final rule, including a new comprehensive APC for observation.
Q: We are an independent outpatient end-stage renal disease clinic. When we administer a blood transfusion (we do not bill for the blood) can we bill HCPCS code A4750 (blood tubing, arterial or venous, for hemodialysis, each) for the tubing used in the procedure and also A4913 (miscellaneous dialysis supplies, not otherwise specified) for miscellaneous supplies pertaining to administering the blood?
CMS introduced several new HCPCS codes and added comprehensive APCs (C-APC), including one for observation, in the 2016 OPPS final rule, released October 30.
CMS finalized its proposals regarding the 2-midnight rule in the 2016 OPPS final rule, including moving responsibility for enforcement and education of the rule from Recovery Auditors to Quality Improvement Organizations (QIO). This latter change occurred October 1, 2015.
Providers know the drill for addressing and operationalizing CMS' annual IPPS and OPPS updates, along with the usual ICD-9-CM and CPT® coding changes. The industry has become used to CMS' timetable for releasing inpatient and outpatient proposed and final rules and knows that it has to be ready to go live with coding, billing, and operational changes October 1 and January 1, respectively.
Q: I have a question about coding infusion/injections in the ED prior to a decision for surgery. A patient comes into the ED with right lower abdominal pain. The physician starts an IV for hydration, gives pain medication injections, then does blood work and an MRI to rule out appendicitis. The blood work comes back with an elevated white blood count, so the patient is started on an infusion of antibiotics. Then the MRI results come in with a diagnosis of appendicitis. So a surgeon is called in to consult and take the patient to surgery. Can we bill the infusions/injections prior to the decision for surgery? I realize that once the decision is made, then the infusion/injections are off limits and are all included in the surgical procedure. But up until that time, can the ED charge the infusions/injections? They are treating the patient’s symptoms and can’t assume the patient will have surgery until the decision is made by the surgeon.
Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, CDIP, COBGC, AHIMA-approved ICD-10-CM/PCS trainer, provided documentation and coding examples for reporting breast care procedures and ICD-10-CM diagnoses.
Charlotte L. Kohler, RN, CPA, CVA, CRCE-I, CPC, ACS, CHBC, discusses how modifiers -59 and -91 differ and what coders need to know to use them when reporting laboratory services.
Q: Our business office wants us to start using modifier -PO (services, procedures, and/or surgeries furnished at off-campus, provider-based outpatient departments) for services that are provided in some of our outpatient departments, but not all. We want to hard code this to our charge description master but are not sure why some services will get this modifier and some won't.
Because CMS has not created any national ED E/M guidelines, providers must create their own criteria for each visit level. CMS has developed a list of 11 criteria that it uses when auditing facility E/M criteria.
Providers have to create their own ED E/M guidelines, which can present a variety of challenges for facilities. For coders, this means an understanding of how to calculate critical care and other factors in order to report the correct visit level.
Q: I have been told by our billers that infusion codes reported in the ED along with an E/M code that has modifier -25 (significant, separately identifiable evaluation and management service on the same day of the procedure or other service) require another modifier. I thought that -25 is the only modifier that should be submitted, unless the provider started a second infusion at a second site on the body. This is the first time I’ve been told the infusion coder need a modifier if the E/M has modifier -25 appended. All of my educational articles tell me that the two can be reported together. Have I missed an update somewhere along the way?
Combination codes in ICD-10-CM will allow coders to report pressure ulcer location and severity in a single code. Jaci Johnson Kipreos, CPC, CPMA, CEMC, COC, CPC-I, and Betty Hovey, CPC, CPC-H, CPB, CPMA, CPC-I, CPCD, review the stages of pressure ulcers and which information coders will have to look for in documentation.
OPPS costs rose approximately $1 billion more than expected in 2014 due to a CMS overestimation of the impact of laboratory packaging changes, according to the 2016 OPPS proposed rule. As a result, CMS proposes a 2% reduction to the 2016 conversion factor. CMS also proposes to expand laboratory packaging from date of service to the claim level.
The 2016 OPPS proposed rule released July 2 is deceptively short, but packs a punch. CMS is proposing the most massive APC reconfiguration and consolidation of APC groups since the beginning of OPPS, says Jugna Shah, MPH, president and founder of Nimitt Consulting, based in Washington, D.C., and Spicer, Minnesota.
The 2016 OPPS proposed rule introduces APC restructuring, new comprehensive APCs, and many other potential changes for next year. Jugna Shah, MPH, and Debbie Mackaman, RHIA, CPCO, CCDS, review the proposals and what they could mean for providers.
Q: I have a question regarding facility coding for evaluation and management (E/M) levels, not for an ED physician, but for facility-level nursing in the ED. If a specialist is called to evaluate or consult on a patient, the nursing intervention is what the facility-level criteria is based on. For example, a patient has difficulty walking, a nurse assists the patient to get an x-ray, takes vitals, does an initial assessment, then provides discharge instructions of moderate complexity. I would code this scenario as a level 3.
Q: We had a patient come into our ED with a severe head injury. To protect his airway, we intubated the patient. Can we report an emergency endotracheal intubation (CPT ® code 31500) and CPR (92950) together if only bagging happens and no chest compressions?
CMS has repeatedly tweaked its logic regarding comprehensive APCs since inception. Dave Fee, MBA, reviews the latest changes regarding complexity adjustments, as well as new and deleted codes.
Coders may need to review the anatomy of the gastrointestinal system and disease processes for gallstones, hemorrhoids, and ulcerative colitis to choose the most specific ICD-10-CM code. Jaci Johnson Kipreos, CPC, CPMA, CEMC, COC, CPC-I, and Shelley C. Safian, PhD, RHIA, CCS-P, COC, CPC-I, explain aspects of anatomy and what coders will need to look for in the documentation.
Although CMS did not propose any changes to the 2-midnight rule in the fiscal year 2016 IPPS proposed rule, it signaled its intention to address short stays in the calendar year (CY) 2016 OPPS proposed rule. CMS followed through by introducing several proposed changes to the 2-midnight rule.
Q: I am a coder in a hospital outpatient setting. Our physicians document drug use in social history. For example, marijuana use is documented as just "marijuana use" without any further information regarding a pattern of use or abuse. Based on that information, can I report ICD-9-CM code 305.20 (cannabis abuse, unspecified)? How would this be reported in ICD-10-CM?
Q: When the surgeon documents excision of a complex pilonidal cyst with rhomboid flap closure, is the flap closure coded separately or is it included in CPT ® code 11772 (excision of pilonidal cyst or sinus; complicated)?
Since CMS introduced comprehensive APCs in January, the agency has continued to tweak the logic and codes included in the process. Dave Fee, MBA, and Judith L. Kares, JD, describe those changes in CMS’ April quarterly updates and review code and edit updates.
Lately I've received a lot of questions from hospitals about how to determine when and if it's appropriate to report an E/M visit code on the same date of service as a scheduled procedure.
Most coding professionals have heard modifier -59 (distinct procedural service) referred to as a modifier of last resort and to be cautious in using this modifier.
Q: Should modifiers for laterality be used for CPT ® code 31624 (bronchoscopy, rigid or flexible, including fluoroscopic guidance, when performed; with bronchial alveolar lavage)?
Q: A patient arrives at the interventional radiology department to have an inferior vena cava (IVC) filter inserted for portal hypertension and an iliac stent for May-Thurner syndrome. The physician is unsuccessful in accessing an appropriate portal vein branch, despite a few attempts to pass a wire into small portal branches, and aborts the placement. The plan is to reschedule and return with a transplenic approach. Do we code the attempted IVC filter placement with modifier -74 (discontinued outpatient procedure after anesthesia administered) and the complete iliac stent procedure? Or do we code the extent of the IVC filter placement (that being venography) with the complete procedure? Or do we only code the completed procedure?
The 2016 OPPS proposed rule is likely to continue CMS' trend of expanded packaging and feature refinements and expansion of comprehensive APCs based on comments CMS has made in prior rules.
The April quarterly I/OCE update from CMS did not defy convention?featuring the typically small number of updates following extensive changes in the previous quarter?but CMS did continue to clarify the logic for comprehensive APC (C-APC) payments.
Q: We have a patient with chronic severe low back pain, etiology unknown, on MS Contin®, an opioid. Due to the patient’s history of drug-seeking behavior and cannabis abuse, the physician orders a drug screen prior to refilling the prescription. With the changes to drug testing codes in 2015, what would be the appropriate laboratory CPT ® codes to report?
Since CMS introduced the four replacements for modifier -59 (distinct procedural service), providers have struggled with how and when to apply them. Gloria Miller, CPC, CPMA, CPPM, and Christi Roberts, RHIA, CCA, AHIMA-approved ICD-10-CM/PCS trainer, provide examples of when these new modifiers can be used.
CMS released updated I/OCE specifications in January with several changes that could require providers to examine claims submitted early in 2015 that include comprehensive APCs (C-APC) to ensure proper payment.
When CMS introduced the -X{EPSU} modifiers in August 2014 to be used in specific instances to replace modifier -59 (distinct procedural service), the agency encouraged "rapid migration" to the new modifiers.
The policies that CMS publishes each year in the OPPS proposed rule don't always come as a surprise. Sometimes, CMS will announce its future intent in a previous rule in order to notify providers about data it is looking at or requesting comments on.
Dave Fee, MBA, identifies updates to CMS' programming logic for comprehensive APCs and provides a step-by-step approach to determine whether a complexity adjustment will be applied.
Q: We are trying to verify whether we should bill for two units of the CPT® code when the provider performs a service with and without magnetic resonance angiography (MRA), such as an MRA of the abdomen, with or without contrast material (code 74185). The description of the MRA CPT codes say "with or without," not with and without for billing all non-Medicare payers. We realize for Medicare we are to use HCPCS codes C8900-C8902.
Q: If a patient is given Reglan ® intravenously at 12:20, 13:00, and 13:20, would this be considered an IV push because the clinician did not document a stop time?
Q: Our electronic health record system only provides for a "yes/no" choice under smoker. How can we capture the additional details necessary for an ICD-10-CM code assignment?
Physician coders won't be able to just report the CPT ® code that best describes the procedure for some digestive system services in 2015. Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CCDS, and Raemarie Jimenez, CPC, CPMA, CPC-I, CANPC, CRHC, explain why some payers, including CMS, may require new G codes for certain procedures and how the G codes map to related CPT codes.
Q: I have a question regarding a National Correct Coding Initiative (NCCI) edit. I reported CPT ® code 80053 (comprehensive metabolic panel) and 84132 (potassium; serum, plasma or whole blood), resulting in an NCCI conflict. This code pair does allow modifier -59 (distinct procedural service) to be appended to one of the codes to be paid for both tests. Does it matter if we append modifier -59 to the primary code or the secondary?\ In my case, sometimes the secondary code is already dropped into the system and now the edit is asking me to append the modifier. Can I add modifier -59 to 80053 whether it's the primary code or not?
The January quarterly I/OCE update includes new modifiers, changes related to expanded packaging, and continued refinement of CMS' skin substitutes categories, but the biggest change for outpatient hospitals is the implementation of comprehensive APCs (C-APC).
The implementation of Comprehensive APCs (C-APCs) in the 2015 OPPS final rule likely wasn't a huge surprise to most providers, given CMS discussed this concept in the 2014 final rule and indicated it expected to implement it the following year.
CMS' January I/OCE update brought many changes, including new codes, status indicators, and modifiers. Dave Fee, MBA, reviewsthe latest changes and when they will be implemented by CMS.
Q: Would it be appropriate to report CPT ® code 75984 (change of percutaneous tube or drainage catheter with contrast monitoring [e.g., genitourinary system, abscess], radiological supervision and interpretation) for the following procedure: A small amount of contrast was injected through the indwelling nephrostomy drainage catheter. This demonstrated the catheter is well positioned within the renal collecting system. There is a small amount of thrombus attached to the tip of the pigtail catheter. The existing catheter was cut and a guidewire was advanced through the catheter into the renal collecting system. The existing catheter was removed over the wire and exchanged for a new 10 French nephrostomy tube. The catheter was secured to the skin with 2-O suture and covered with a sterile dressing.
In the 2015 OPPS final rule, CMS introduced a new modifier for services provided in an off-campus, provider-based clinic. Jugna Shah, MPH, and Valerie Rinkle, MPA, review when the modifier will become required and how it should be reported.
Q: Is it correct to append modifier -52 (reduced services) to a procedure code when the physician performed the procedure, but did not find a mass? This was unexpected, so the surgeon went deeper into the subcutaneous tissue and still did not find anything. This is the outpatient note for a patient with a history of breast cancer and a new lump on her arm with an indeterminate ultrasound: Under local anesthesia and sterile conditions, a vertical incision was made over the area of the palpable abnormality. We dissected down beneath the subcutaneous tissues. I could encounter no definitive mass or lesions in this area. We went down to the fascia of her bicep. Her biceps appear normal, and the skin and subcutaneous tissue appear normal. My presumption is that this represented some sort of venous anomaly, and I either popped it or incised it during our entry into the skin, and it is now resolved. Would CPT ® code 24075-52 (excision, tumor, soft tissue of upper arm or elbow area, subcutaneous; less than 3 cm) be correct to report?
Drug administration coding and billing remains a challenge despite no code changes in six years. Jugna Shah, MPH, and Valerie RInkle, MPA, examine how to apply the new -X{EPSU} modifiers with drug administration codes and review other common questions they receive about injections and infusions.
In December 2014, CMS posted a document on its Advisory Panel on Hospital Outpatient Payment (HOP Panel) website outlining the hospital outpatient therapeutic services that were recently evaluated for a change in supervision levels. The three-page document contains a chart that includes the HCPCS code, the level of supervision required for coverage, and the effective dates of the changes for various services.
Q: When would we use codes from ICD-10-CM category E13 (other specified diabetes mellitus)? If it's secondary diabetes but not due to an underlying condition or drug and is not chemically induced, what kind of diabetes could it be?
CMS expanded packaging and finalized Comprehensive APCs in the 2015 OPPS final rule. Jugna Shah, MPH, and Valerie Rinkle, MPA, analyze the changes and the potential impact on providers.
As CMS pushes the OPPS from a fee-for-service program toward more of a true prospective payment system, financial impact analysis of changes, departmental budgeting, and forecasting has become more complicated each year.
In a concerted effort to move healthcare payments to a system of "quality over quantity," CMS finalized policies that greatly expanded packaging for outpatient providers in the 2015 OPPS final rule. It also introduced complexity adjustments with comprehensive APCs (C-APCs).
Q: If the physician does not perform a formal myelography and just administers an injection before the patient goes straight for computed tomography (CT), which CPT ® code would we report in 2015? The 2015 combination codes are for use when the same radiologist or physician who performs the injection reads his or her own study.
Q: I have a question regarding CPT ® code 99184 (initiation of selective head or total body hypothermia in critically ill neonate, includes appropriate patient selection by review of clinical, imaging, and laboratory data, confirmation of esophageal temperature probe location, evaluation of amplitude EEG, supervision of controlled hypothermia, and assessment of patient tolerance of cooling) in the 2015 CPT Manual . What if the neonate is in the hospital for several weeks? The total body hypothermia is performed, the baby improves, but remains in the hospital and then needs the procedure performed a second time. Can we report it a second time if several weeks have elapsed?
Beginning January 1, 2015, physicians will no longer need to provide certification for an inpatient admission unless the admission is expected to last for at least 20 days or the case is an outlier.
Q: We have a patient diagnosed with neuropathy due to poorly controlled insulin-dependent Type 1 diabetes mellitus. What should we report in ICD-10-CM?
Nearly 30% of Medicare patients are enrolled in Medicare Advantage (MA) programs, which come with specific coding and documentation challenges. Elaine King, MHS, RHIA, CHP, CHDA, CDIP, FAHIMA, and Bonnie S. Cassidy, MPA, RHIA, FAHIMA, FHIMSS, highlight key requirements for reporting diagnoses that map to Hierarchical Condition Category codes, the basis of MA plans.
Q: I work in a large, provider-based orthopedic clinic with a rheumatology department that has many patients who are very ill with several comorbid conditions. Does the physician need to document every comorbid condition that impacts his or her medical decision making for each encounter? Do we need to code every comorbidity each time in order to meet hierarchical condition category (HCC) requirements?
Even before ICD-10-CM was delayed until October 1, 2015, the quality of physician documentation to accommodate the new code set was a top concern for the healthcare industry.
Editor's note: Jugna Shah, MPH, president and founder of Nimitt Consulting, writes a bimonthly column for Briefings on APCs, commenting on the latest policies and regulations and analyzing their impact on providers.
When is a mammogram a screening procedure and when does it qualify as a diagnostic test? Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, outlines the differences between the two and what to look for in the documentation.
Q: Do any general guidelines exist for queries on outpatient services? We are beginning the process of developing such a query system for our hospital outpatient services and clinical documentation team.
Steven Espinosa , CCS , AHIMA-approved ICD-10-CM/PCS trainer, and Denise Williams, RN, CPC-H, outline the anatomy of the upper gastrointestinal system and how anatomical details, along with the provider's approach and intent, help determine the proper procedure code.
Editor's note: Andrea Clark-Rubinowitz, RHIA, CCS, CPCH , has more than 30 years of experience working with healthcare professionals, information systems, hospital coding, and operational and compliance training. She founded and led Healthcare Revenue Assurance Associates from 2001 to 2014. Contact her at 954-465-0968 or aclark5678@gmail.com .
Q: A patient was in a hyperbaric oxygen chamber for eight minutes and the physician had to abort the treatment because the patient was feeling anxious. Which HCPCS/CPT ® code should the hospital bill: HCPCS code C1300 (hyperbaric oxygen under pressure, full body chamber, per 30 minute interval) or an E/M code? Which code should the supervising physician bill: CPT code 99183 (physician or other qualified healthcare professional attendance and supervision of hyperbaric oxygen therapy, per session) or an E/M code?
CMS has instructed MACs to reprocess claims and providers to reimburse beneficiaries due to a miscalculated copayment for stereotactic radiosurgery, according to the October update to the OPPS and Integrated Outpatient Code Editor (I/OCE).
Q: What if the provider states that diabetes is due to the adverse effects of a drug, but doesn't tell us which drug? How do we report that in ICD-10-CM?
Q: We're not sure what to report in this situation: A patient comes to the ED and goes into respiratory failure. The respiratory therapist comes in to put patient on a vent in the ED, then the patient is transferred to another facility. We can’t report CPT ® code 94002 (ventilation assist and management, initiation of pressure or volume preset ventilators for assisted or controlled breathing; hospital inpatient/observation, initial day) because it is for inpatient/observation, per the definition. We wondered about using 94660 (continuous positive airway pressure ventilation [CPAP], initiation and management) for the CPAP. The lay description seems to be basically the same as 94002, except for “applies to ventilation assistance using adjustments in volume and pressure on the initial day…" Would 94660 be appropriate?
The ICD-10-CM delay has at least one silver lining: the ability to spend more time on coding and documentation requirements before implementation. Providers may want to also think about aligning their ICD-10-CM efforts with outpatient clinical documentation improvement (CDI) during this time. Elaine King, MHS, RHIA, CHP, CHDA, CDIP, examines the benefits and challenges of outpatient CDI programs.
The 2015 OPPS proposed rule includes new Comprehensive APCs, increased packaging, and many other changes. Kimberly Anderwood Hoy Baker, JD, and Jugna Shah, MPH , review the proposed rule and policies that may be finalized by CMS.
Evaluation and management (E/M) services are one of the top areas of review by federal auditors. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC , writes about common errors found in audits and how providers can take steps to correct them.
Modifier -25 (significant, separately identifiable E/M service by the same physician on the day of a procedure) is used to distinguish visits from procedures on the same day. It is not used to distinguish observation from a visit service on the same day.
