When CMS releases rules, the length can be intimidating. But even at a relatively slim 700 pages, the 2015 OPPS proposed rule isn't able to include details on each of the changes CMS is planning. This is probably a good thing?otherwise the rules could be thousands of pages long. Updates like codes being moved around or status indicators changing often aren't described in full in the narrative text, necessitating a deeper look at the addenda CMS releases as Excel® files on its website.
CMS refined and updated its Comprehensive APC policy in the 2015 OPPS proposed rule released July 3, adding a new complexity adjustment factor. CMS also proposes significantly expanding the packaging of ancillary services. Additionally, the proposed rule includes a significant change to requirements related to inpatient physician certification.
Q: We're wondering about how to use CPT ® code 73225 (magnetic resonance angiography [MRA], upper extremity, with or without contrast material) in our hospital. When providing an MRA of an upper extremity with and without contrast material, should we bill this service twice (since CPT indicates with or without contrast material) or only once?
Hospitals will still use CPT ® codes to report procedures after ICD-10 is implemented, but some will also code with ICD-10-PCS. Andrea Clark, RHIA, CCS, CPC-H , reviews the advantages and challenges outpatient facilities may face when using ICD-10-PCS.
Q: My physicians perform procedures in the office such as angioplasties, catheter insertions, venograms, and repairs of grafts and fistulas. What is the proper way to code the medications they administered during the procedures?
The July quarterly I/OCE update from CMS brought few new APCs or edit updates, but did deliver new modifier -L1. Hospitals will use the new modifier to submit outpatient laboratory tests paid under the Clinical Laboratory Fee Schedule (CLFS) in certain circumstances to claim separate payment.
"Sometimes the questions are complicated and the answers are simple." ?Dr. Seuss This quote seemed an appropriate way to begin a discussion about outpatient encounters and ICD-10-PCS. You see, outpatient procedures will still be coded using CPT ® /HCPCS?the HIPAA-approved code set for reporting hospital outpatient procedures?regardless of when ICD-10 is implemented.
Q: A patient comes into the ED with sickle cell crisis and is in a lot of pain. The physician states the patient needed “aggressive” pain control for treatment, because what was given in the beginning provided only minimal relief. Could I code using CPT ® code 99285 (ED visit for evaluation and management of a patient, including a comprehensive history, comprehensive exam, and high complexity medical decision making)?
The July quarterly I/OCE update from CMS brought few new APCs or edit updates, but did deliver a new modifier. Debbie Mackaman, RHIA, CHCO, Jugna Shah, MPH , and Denise Williams, RN, CPC-H , explain how to use the modifier, as well as the impact of APC changes.
Q: We are coding for pain management procedures and have been doing dual coding in ICD-9-CM and CPT ®. With a medial branch block ablation at two levels for L3-L4 and L4-L5 for a bilateral injection, we are coding: ICD-9-CM procedure code 04.2 (destruction of cranial and peripheral nerves) CPT codes 64635 (destruction by neurolytic agent, paravertebral facet joint nerve[s], with imaging guidance [fluoroscopy or CT]; lumbar or sacral, single facet joint) and 64636 (destruction by neurolytic agent, paravertebral facet joint nerve[s], with imaging guidance [fluoroscopy or CT]; lumbar or sacral, each additional facet joint [List separately in addition to code for primary procedure]), each with modifier -50 (bilateral procedure) appended. What would be your recommendation for the ICD-10-PCS code? Currently we are coding 015B3ZZ (destruction, lumbar nerve, percutaneous) twice. We are not sure if we should be picking this code up twice or only once.
Documentation and billing for observation stays has come under increased scrutiny from the OIG, though many hospitals have struggled with changing regulations and frequently updated guidance.
Q: I work for general surgeons. Here is a common scenario: The surgeon is called in to see patient in the ED for trauma or consult. The patient is admitted, but our physician is not the admitting physician. I would tend to bill the ED code set, but do I have to use the subsequent hospital care codes instead?
Q: If the clinical impression is physical assault, vomiting, blunt injury to abdomen, and head injury with loss of consciousness, can I code the history of hypertension, diabetes mellitus, headache, bipolar disorder, and depression?
On July 1, CMS will implement a variety of changes to current supervision requirements as recommended by the Hospital Outpatient Payment Panel. Debbie Mackaman, RHIA, CHCO , reviews the panel's recommendations, and which CMS plans to accept or reject.
CMS made relatively few changes in the April quarterly I/OCE update, introducing four new APCs, deleting one, and reclassifying several skin substitute codes.
Hospital outpatient therapeutic services, such as ED or clinic visits, that are paid under the OPPS or to critical access hospitals (CAH) on a cost basis must be furnished "incident to" a physician's service to be covered.
Q: I read that CPT ® code 20680 (removal of implant; deep, e.g., buried wire, pin, screw, metal band, nail, rod, or plate) is commonly used for deep hardware removal. What would be the proper code for removal on one screw that has already made its way out, is not under any muscle, and is easy to visualize?
The April quarterly I/OCE update brought relatively few changes, though CMS has continued to refine skin substitute reporting. Dave Fee, MBA, reviews the updated skin substitute categories, as well as updates to laboratory billing.
Q: My office often has denials of evaluation and management (E/M) visits with our OB patients when using HCPCS modifier -GB (claim being resubmitted for payment because it is no longer covered under a global payment demonstration). Would coding with V22.2 (pregnant state, incidental) as a secondary diagnosis possibly alleviate this issue?
Since January, providers have been struggling to reconcile conflicts between CMS' rules and regulations and those published by the CPT® Manual and other AMA publications.
In January, I wrote about the perfect storm that led to the release of the 2014 OPPS final rule. We endured a later-than-usual release, errors in the data files and a release of updated files, a government shutdown, and a vastly shortened window between the release of the final rule and implementation on January 1. Judging by the confusion among providers?and corrections and clarifications coming from CMS on what seems like a weekly basis on a wide range of issues?we're still not in the clear.
Providers struggle to reconcile conflicts between recent CMS regulations and the CPT® Manual and other AMA publications. Jugna Shah, MPH , Valerie A. Rinkle, MPA , and Linda S. Dietz, RHIA, CCS, CCS-P , look at specific areas of confusion and how to code them accurately.
Q: I have been told to use the general surgery CPT ® codes in the 20000 series for reporting excisions of sebaceous cysts when the surgeon must cut into the subcutaneous layer. I don’t agree with this, since the 20000 codes do not give ICD-9-CM code 706.2 (sebaceous cyst) as a billable diagnosis code. Because a sebaceous, epidermal, or pilar cyst begins in the skin and may grow large enough to press into the subcutaneous layer, I think we should report an excision code from the 11400 series, and if need be, the 12000 codes for closure.
Shelley C. Safian, PhD, CCS-P, CPC-H, CPC-I, reviews which diagnosis codes, in both ICD-9-CM and ICD-10-CM, Medicare recently approved to provide medically necessary for inserting pacemaker systems.
Q: My question is about the time interval requirement of the CPT ® add-on code 96376 (each additional sequential intravenous push of the same substance/drug provided in a facility [list separately in addition to code primary procedure]), which says that more than 30 minutes must pass between administrations of same substances in order to report it. In our ED, cardiac patients are frequently started on heparin—a bolus given for less than 16 minutes and a drip given over several hours. These are frequently charted in the electronic record as having been given at the same time. In this case, is it still appropriate to report 96365 (intravenous infusion, for therapy, prophylaxis, or diagnosis; initial, up to 1 hour) for the first hour of drip and 96376 for the bolus, or must the administration be given greater than 30 minutes apart?
The January 2014 quarterly I/OCE update included nearly 400 new HCPCS Level II codes, but the most significant changes for providers may center on relatively few codes, as a result of modifications CMS made in the 2014 OPPS final rule.
Our experts answer questions on payment rates for scans, bronchodilator treatment, the inpatient-only list, stereotactic radiosurgery, bill exposure with arthrodesis, and more.
While many of the code changes in the 2014 CPT® Manual surgical sections involve bundling together common procedures, the major changes in the Radiology and Laboratory sections involve updates for newly recognized technologies and drugs.
Hierarchical Condition Category (HCC) coding may be a foreign concept for some coders, but making sure documentation for Medicare Advantage patients supports it can be critical. Holly J. Cassano, CPC , discusses what criteria needs to be met for complete documentation.
Changes implemented by the 2014 OPPS Final Rule resulted in the addition and deletion of many codes in the January I/OCE update. Dave Fee, MBA , reviews some of the most important modifications, including changes to evaluation and management services and device reporting.
Q: When coding excision of a breast mass with needle localization using stereotactic guidance, we report CPT ® code 19125 (excision of breast lesion identified by preoperative placement of radiological marker, open; single lesion) and new code 19283 (placement of breast localization devices, percutaneous; first lesion, including stereotactic guidance). The 3M system says Medicare NCCI edits consider this separate reporting of codes that are components of the comprehensive procedure if billed for services provided to the same beneficiary by the same physician on the same day. These codes will be rebundled by the Medicare payer and payment will be based on code 19125 only. Does that mean to only report 19125 for this kind of case? If there is an excision of a lesion by one surgeon and needle localization done by a radiologist, can we report 19125, with 19283 and modifier -59 (distinct procedural service)? We can’t find any official reference for this issue for 2014. How do we code excision of a breast mass with needle localization now?
Q: I am auditing a note for a fusion. The note lacks detail, therefore is hard to justify. The patient had a prior hardware placement. The note describes dissecting down, debridement of necrotic bone, and tissue work done. This is the entire note, after describing dissection, “Vigorous irrigation with 10 liters of saline and antibiotics was carried out. Hemostasis was maintained. The right S1 screw and rod portion was removed as it was notably loose. Additional decortication and onlay bone grafting was performed at L1-S1. Drains were placed…” They coded: 22612 (arthrodesis, posterior or posterolateral technique, single level; lumbar) Add-on code 22614 (each additional vertebral segment) x4 22852 (removal of posterior segmental instrumentation) In the procedures performed area of the note, they state: Hardware removal, lumbar Revision fusion L1-S1 with onlay bone graft Irrigation and debridement of lumbar spine wound Since there is nothing in the note regarding autografting, I assume this is an allograft? Should this be coded? Also is that documentation enough to justify arthrodesis? Modifier -GC (this service has been performed in part by a resident under the direction of a teaching physician) was appended, although the language was not added for this. I can only assume a resident dictated this.
CMS has been making it clear over the years that packaging would become a larger and larger part of OPPS, and in calendar year (CY) 2014 CMS made good on this.
When an NCCI edit occurs on a claim, providers can go directly to CMS’ website and download the latest edits to pinpoint why the edit occurred and what codes may be conflicting.
Q: Can we report CPT ® code 32609 (thoracoscopy; with biopsy of pleura) with 32666 (thoracoscopy, surgical; with therapeutic wedge resection, initial unilateral)? We have researched thoroughly and were not able to find a clear answer.
Debbie Mackaman, RHIA, CPCO, and Sarah L. Goodman, MBA, CHCAF, CPC-H, CCP, FCS, discuss the purpose of medically unlikely edits (MUEs) and how they are calculated by CMS.
Q: I have a question regarding CPT® code 22558 (arthrodesis, anterior interbody technique, including minimal discectomy to prepare interspace; lumbar). I perform this exposure as a vascular surgeon, with the orthopedic surgeon preforming the spinal surgery. If I perform an anterior exposure for a spine deformity using code 22808 (arthrodesis, anterior, for spinal deformity, with or without cast; two to three vertebral segments), do I bill 22558 for the exposure?
Jugna Shah, MPH, and Valerie A. Rinkle, MPA, examine the 2014 OPPS Final Rule and explain which services are now packaged, including drugs and biological that function as supplies when used in diagnostic or surgical procedures, clinical diagnostic lab tests, and device removal procedures.
In addition to increased packaging and collapsing of E/M clinic visit level CPT ® codes in the 2014 OPPS -Final Rule, CMS made additional changes that will have an immediate impact on reimbursement or require operational changes for providers.
One of the most radical changes CMS proposed in this year’s OPPS was to collapse the five levels of E/M CPT ® codes and replace them with three new HCPCS G-codes, including one APC for all clinic visits, one for all Type A ED visits, and one for all Type B ED visits.
In the 2014 OPPS Final Rule, CMS offered the following -example for billing a laboratory test on the same date of service as the primary service, but ordered for a different purpose than the primary service by a practitioner different than the practitioner who ordered the primary service.
Q: I am looking for information about to how to bill for a transnasal-endoscope approach in removing a skull-base tumor. I have never been comfortable with the doctors wanting to use CPT ® 61600 (resection or excision of neoplastic, vascular or infectious lesion of base of anterior cranial fossa; extradural) to bill a non-invasive procedure. I am perplexed about which CPT code(s) to report for this type of procedure.
CMS did not finalize a proposal to collapse all evaluation and management visits into three codes, but did change clinic visit level coding. Jugna Shah, MPH, and Valerie A. Rinkle, MPA, review some of the major changes to E/M levels for 2014 and the new codes introduced. introduced.
Skin and dermatology coding includes unique challenges with its extensive terminology and the need to calculate wound and lesion sizes. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC , discusses common documentation problems and how coders can improve their efficiency and proficiency.
Q: A patient presents with lower back pain and the physician documents findings of stenosis, degenerative “changes,” and mild facet arthropathy. Which diagnosis codes should we report? I would code 724.02 (stenosis, lumbar region, without neurogenic claudication) and 721.3 (lumbosacral spondylosis without myelopathy) for the facet degeneration. Another coder has stated that I cannot code 724.02, as the 721.3 diagnosis code will exclude the use of 724.02. Can you help with this scenario?
Our experts answer questions on port reassessment, laparoscopies, reporting multiple biopsies, rejected drug claims, post-reduction film, nipple revisions, and more.
The number of patients using Medicare Advantage (MA) is rapidly growing, making Hierarchical Condition Categories (HCCs) an increasingly important concept for revenue cycle staff to understand in order to guarantee reimbursement.
Q: When we send in a claim for CPT ® code 29898 (arthroscopy, ankle, surgical; debridement, extensive) to Aetna with modifier –AS (non-physician assisting at surgery) for our physician’s assistant, Aetna will deny the claim saying “assistant not covered.” However, that procedure code says it is covered for an assistant surgeon. I have sent appeal after appeal and printouts from the American College of Surgeon’s (ACOS) Coding Today website showing this procedure code is payable to Aetna, and Aetna still denies the claim. Medicare pays on this claim, why wouldn’t Aetna?
Q: How does CPT ® define "final examination" for code 99238 (hospital discharge day management; 30 minutes or less)? Does the dictation have to include an actual detailed examination of the patient? We have been coding 99238 for discharges that include final diagnosis, history of present illness, and hospital course along with discharge labs, medicines, and home instructions. Very few contain an actual exam of the patient. Have we been miscoding all this time?
Jugna Shah, MPH, and Valerie A. Rinkle, MPA, look at drug administration coding, beginning with documentation, in order to highlight the information coders need to ensure accuracy. They also review the hierarchy coders must follow when coding for injections and infusions.
During the January injections and infusions audio conference, Jugna Shah, MPH, president and founder of Nimitt Consulting in Washington, D.C., and Valerie A. Rinkle, MPA, associate director with Navigant Consulting in Seattle, reviewed these scenarios.
Healthcare providers are used to regularly changing guidelines and regulations that drastically alter their processes for coding and billing. Despite few guideline changes since 2008, drug administration still frequently causes confusion because of all the necessary factors to properly document, code, and bill the services.
Q: When a procedure is performed by laparoscopy, but only a code for the open approach is listed, do you use the unlisted procedure code? For example, the physician documented: laparoscopic pyloromyotomy, hypertrophic pyloric stenosis. We used CPT ® code 43520-22 (pyloromyotomy, cutting of pyloric muscle, Fredet-Ramstedt type operation, with the increased procedural services modifier) but the coding department corrected with 43659 (unlisted laparoscopy procedure, stomach). We are a pediatric surgical practice. I feel because the procedures are very common and performed often, our revenue will drop by using unidentified procedure codes, but I want to code them correctly.
Q: We recently had a situation where a patient had come in to have his port re-assessed. He had been complaining of the port being difficult to access. Preliminary x-ray showed the port accessed, with great blood return. Patient has an allergy to IV contrast, so we just flushed the port, and did not give the contrast. The port remained accessed. How do we code this? Do we use 36598 (contrast injection[s] for radiologic evaluation of existing central venous access device, including fluoroscopy, image documentation and report) with a modifier -52 (reduced services)? The other option is a modifier -73 (discontinued outpatient procedure prior to anesthesia administration) or -74 (discontinued outpatient procedure after anesthesia administration). However we have no documentation regarding anesthesia, and I'm not sure the patient would even get anesthesia for a procedure such as this.
Coders select E/M levels based on criteria developed by their organization. CMS has proposed a significant change to E/M coding-replacing the current 20 E/M levels for new patients, existing patients, and ED visits with three G codes-but that change would only apply to Medicare patients and only to the facility side.
Our experts answer questions about followup visits in the ED, skin substitutes, flu vaccines, osteoporosis and fractures in ICD-10-CM, ICD-10-CM external cause code, modifier for discontinued cardioversion, and modifier -25
Some of the most sweeping changes in OPPS history were proposed in the 2014 rule, including new packaging rules, quality measures, and changes to evaluation and management. Jugna Shah, MPH, and Dave Fee, MBA, look at some of the changes and how they could impact providers.
Q: The patient has had a previous bilateral mastectomy and is now coming in for a revision of bilateral areola with a dermal fat graft to the left nipple and excision of excessive skin and subcutaneous tissue from both breasts. This would be CPT ® code 19380 (revision of reconstructed breast) with modifier -50 (bilateral procedure) and 19350-50 (nipple/areola reconstruction) for both procedures. I cannot locate information that tells me if the nipple revision on the reconstructed breast is part of the 19380 or can be separately coded with 19350.
Packaging still causes confusion amongst healthcare providers and the number of packaged services will greatly expand if CMS finalizes certain parts of the 2014 OPPS proposed rule. Valerie A. Rinkle, MPA, and Kimberly Anderwood Hoy Baker, JD, CPC , discuss what changes could come in 2014 and how to avoid common packaging errors.
Jeanne L. Plouffe, CPC, CGSC , and Jennifer Avery, CCS, CPC-H, CPC, CPC-I , review procedures performed on the gallbladder and how to determine the correct ICD-9-CM diagnosis codes.
Despite its apparently straightforward definition in the CPT ® Manual , modifier -59 (distinct procedural service) can be deceptively difficult to append properly.
CMS added modifier -AO (provider declined alt payment method) and new HCPCS codes to the I/OCE as part of the October 2013 quarterly update found in Transmittal 2763.
Our experts answer questions about NCCI edits for injections, modifier -25, modifier -59, laminotomy with insertion of Coflex distraction device, billing mammogram for needle placement, and auditing electronic orders.
CMS’ proposed 2014 OPPS rule is set to introduce many changes, such as more packaged services, including lab tests and add-on codes. Jugna Shah, MPH; Dave Fee, MBA; Kimberly Anderwood Hoy, JD, CPC; and Valerie A. Rinkle, MPA, offer their insight on what effect these changes could have for providers.
Modifiers are sometimes essential to ensure proper payment, but choosing the correct one can be tricky. Sarah L. Goodman, MBA, CHCAF, CPC-H, CCP, FCS; Katherine Abel, CPC, CPMA, CEMC, CPC-I; and Susan E. Garrison, CHCA, CHCAS, CCS-P, CHC, PCS, FCS, CPAR, CPC, CPC-H, discusssome confusing modifiers and how to use them accurately.
Q: A patient comes into the ED with chest pain. An EKG (CPT® code 93005) is performed. The patient goes directly to the catheterization lab for catheterization (code 93454). Is a modifier appropriate for the EKG?
Q: We have a patient with documented age-related osteoporosis. She bent over to pick up a newspaper from a table and fractured a vertebrae. Should we code the fracture as pathologic or traumatic?
Our experts answer questions about billing vasectomy and sperm analysis , coding for ED visit when the patient is admitted for surgery, billing glucose reading before a PET scan, documentation required for the functional limitation codes, and appropriate reporting of observation.
E/M coding and reimbursement for hospital outpatients could change dramatically if CMS finalizes its proposal to replace current E/M CPT ® codes with three G-codes.
Evaluation and management (E/M) coding and reimbursement for hospital outpatients could change dramatically if CMS finalizes its proposal to replace current E/M CPT ® codes with three G codes. Dave Fee, MBA, Peggy S. Blue, MPH, CCS-P, CPC, Jugna Shah, MPH, Kimberly Anderwood Hoy, JD, CPC, Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CCDS, and Valerie A. Rinkle discuss the possible impact if CMS finalizes its proposal.
Q: The patient comes in for a cardioversion, but the international normalized ratio results were unsatisfactory. The physicians canceled the cardioversion. Would modifier -73 (discontinued outpatient/hospital ambulatory surgery center procedure prior to the administration of anesthesia) be appropriate?
In January 2013, CMS introduced 42 therapy functional reporting G codes (nonpayable), but instituted a six-month trial period. That grace period ended July 1. Denise Williams, RN, CPC-H, Dave Fee, MBA, and Debbie Mackaman, RHIA, CHCO, explain how to report these G codes and their related functional modifiers.
Medical necessity is as simple as it sounds and it isn’t important just for inpatients. Shelley C. Safian, PhD, CCS-P, CPC-H, CPC-I, reviews the importance of establishing medical necessity for outpatient services.
Q: A clinician goes to a patient's home and does not perform an evaluation and management, but performs a catheter replacement. How should we code this encounter?
In January 2013, CMS introduced 42 therapy functional reporting G codes (nonpayable). These G codes are to be reported in conjunction with therapy services (physical, occupational, and speech). CMS also introduced seven complexity/severity modifiers to be used with these G codes.
Eight CPT ® codes for multianalyte assays with algorithmic analyses (MAAA) procedures are now classified as not covered under OPPS (status indicator E), retroactive to January 1, 2013. These codes are now subject to I/OCE edit 9.
Providers setting charges based on an understanding of their costs is not a new concept, says Jugna Shah, MPH, president and founder of Nimitt Consulting. However, providers struggle with this or fail to do it correctly, and then stand to deteriorate their future payment rates since CMS relies on provider data to set payment rates not only for inpatient and outpatient services, but also for laboratory services.
Coders append modifiers to claims every day, but use some modifiers less frequently than others. Lori- Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, discusses the proper use of two less common modifiers, modifiers -62 and -66.
CMS’ July update to the Integrated Outpatient Code Editor features new codes, new APCs, and a new modifier. Dave Fee, MBA, explains the most noteworthy changes for this quarter.
CMS is reexamining inpatient criteria because it has seen a significant increase in the number of patients spending more than 24 hours in observation. Providers are worried that a Recovery Auditor will deny a short inpatient stay for lack of medical necessity and recoup payment years later. So instead, some facilities place patients in observation for longer time periods.
Q: My question pertains to CPT® vasectomy code 55250. This code includes "unilateral or bilateral (separate procedure) including postoperative semen examination(s).” The CPT manual states that a reference laboratory that performs the semen analysis may bill separately for this service. May we bill CPT code 89321 ( semen analysis; sperm presence and motility of sperm, if performed .) in addition to 55250 when the laboratory performs the semen analysis and the surgeon only performs the vasectomy?
Outpatient providers are beginning to see more and more medical necessity audits, especially in the ED and for evaluation and management (E/M) levels. Caral Edelberg, CPC, CPMA, CAC, CCS-P, CHC, AHIMA-Approved ICD-10-CM/PCS Trainer, and Joanne M. Becker, RHIT, CCS, CCSP, CPC, CPC-I, AHIMA approved ICD-10-CM/PCS trainer, review the guidelines for ED E/M services and highlight common audit risk areas.
CMS is reexamining inpatient criteria because it has seen a significant increase in the number of patients spending more than 24 hours in observation. James S. Kennedy, MD, CCS, CDIP, and Kimberly Anderwood Hoy, JD, CPC, discuss CMS’ proposed changes and how they could affect outpatient observation services.
