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.
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.
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.
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?
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?
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.
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.
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).
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.
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.
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.
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.
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?
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.
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).
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?
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?
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.
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 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.
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.
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.
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.
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.
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?
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?
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.
"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.
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.
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?
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.
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?
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.
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: 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?
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?
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.
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.
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.
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.
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?
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.
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.
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.
