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.
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?
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.
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.
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
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.
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.
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.
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.
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?
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: 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.
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?
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.
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.
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.
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 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?
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.
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.
Coders use the same CPT ® codes to report outpatient services whether they are coding physician or facility services. Jaci Johnson, CPC,CPC-H,CPMA,CEMC,CPC- I, and Judy Wilson, CPC, CPC-H, CPCO, CPC-P, CPPM, CPCI, CANPC, CMRS, examine the similarities and differences between coding in the two settings.
Q: We get an NCCI edit when billing an intramuscular/subcutaneous injection (CPT® code 96372) during the same encounter as billing an injection, infusion, or hydration. Should we append modifier -59 (distinct procedural service)? Does it matter if an IV line is already in place before intramuscular/subcutaneous administration?
Our experts answer questions about hydration, excludes notes in ICD-10-CM, L codes for neurostimulator devices, physician supervision for hyperbaric oxygen therapy, E/M service with wound care, and pass-though drugs.
Providers were glad to see CMS' ruling (CMS-1455-R) released March 13 (published in the Federal Register on March 18), which allows full Part B payment for inpatient stays that had been denied as not reasonable and necessary. The ruling had very few details on how the process would work, but on March 22, CMS published Transmittal R1203OTN instructing contractors and providers on the details.
Q: A patient suffered a nontraumatic intracerebral hemorrhage six months ago and is now being seen for long-standing aphasia as a result of the stroke. How would we code this in ICD-10-CM?
CMS corrected edit 84, added five APCs, deleted two APCs, and changed the description of another as part of the April updates to the I/OCE. Dave Fee, MBA, reviews the most significant changes CMS implemented
Our experts answer questions about modifiers for diagnostic interventional procedures, Medicare recognition of CPT ® code 9066, reporting add-on code for psychotherapy with interactive complexity, reporting G0378 for all payers, and wound care coding.
Successful appeals can actually lead to CMS policy changes. Facilities have been successfully appealing to receive Part B payments after a Medicare review contractor denied a Part A stay as not medically necessary. As a result, CMS is changing its policy on rebilling for Part B services.
CMS corrected edit 84, added five APCs to the I/OCE, deleted two APCs, and changed the description of another as part of the April updates to the I/OCE. In addition, CMS deleted all of the genetic testing modifiers, retroactive to January 1.
Q: If a patient has a spinal deformity on L5-S1 and we use the appropriate codes from 2280X and then the physician performs an arthrodesis/fusion on the same level, can we bill the appropriate fusion codes (225XX-226XX) as well? My impression is no, but I would love to get some insight into this question.
Gloria Miller, CPC, vice president of reimbursement services for Comprehensive Healthcare Solutions, Inc., located in Tacoma, Wash, created this quick reference for HCPCS Level 1 modifiers commonly used in wound care coding.
Q: A physician's office collects a pap specimen and sends the specimen to the hospital lab for processing. The physician's office lists ICD-9-CM code V72.31 (general gynecological examination with or without Papanicolaou cervical smear) as the diagnosis for this service. What is the proper diagnosis code for the hospital to use for billing when only processing the specimen?
Q: We received an outpatient radiology report (exam performed 7/11/12) where the radiologist states: CLINICAL INDICATION: LUMBOSACRAL NEURITIS EXAM: LUM SPINE AP/LAT CLINICAL STATEMENT: LUMBOSACRAL NEURITIS COMPARISON: MAY 23, 2012 FINDINGS: There is posterior spinal fusion L-3-L-5 with solid posterolateral bridging bone graft. Pedicle screws and rods are stable in position. There are bilateral laminectomy defects at L3-L-4. The vertebral body and disc space heights are preserved. The spinal alignment is maintained without evidence of spondylolisthesis. No acute fracture is identified. No lytic or blastic lesions are seen. The sacroiliac joints are unremarkable. IMPRESSION: Stable postsurgical changes with solid posterolateral fusion graft. Would you use the following ICD-9 codes: V67.09, 724.4. or 724.4, V45.4? Our coders disagree.
CMS is making a significant change to the Medically Unlikely Edits (MUE) by changing some of them from line-item edits to date-of-service edits, effective April 1. Jugna Shah, MPH, Kathy Dorale, RHIA, CCS, CCS-P, John Settlemyer, MBA/MHA, and Valerie Rinkle, MPA, explain how the change could affect coding and reimbursement.
With no national guidelines in place for facilities to use to determine evaluation and management (E/M) level, coders must apply their facility’s guidelines when coding an outpatient visit. Caral Edelberg, CPC, CPMA, CAC, CCS-P, CHC, and Joanne M. Becker, RHIT, CCS, CCS-P, CPC, CPC-I, use three ED case studies to highlight potential pitfalls for ED E/M leveling.
CMS is making a significant change to the Medically Unlikely Edits (MUE) by changing some of them from line-item edits to date-of-service (DOS) edits, effective April 1.
Our experts answer questions about, modifier -25, cardioversion performed during an ED code, denials for multiple port film line items, and procedure discontinued after administration of anesthesia.
Q: A patient received Toradol 30 mg IV and Zofran 4 mg IV at 14:38. He also had normal saline wide open with documented start of 14:30 and stop of 15:40. Is the hydration chargeable as 96361 (intravenous infusion, hydration; each additional hour) even though the initial service is not 90 minutes? Is the hydration a concurrent service?
CMS added 410 new codes and seven new therapy and patient condition modifiers to the Integrated Outpatient Code Editor (I/OCE) as part of the January 2013 update. Dave Fee, MBA, highlights the key changes to the I/OCE.
In the coding world, it’s a never-ending clash that can cause compliance concerns—facility vs. professional. Kimberly Anderwood Hoy, JD, CPC , and Peggy Blue, MPH, CPC, CCS-P, explain how coders in each setting use different codes for the exact same services based on the payment systems, the rules, and how each setting applies those rules.
Q: In ICD-9-CM we only have one type of Excludes note. ICD-10-CM uses Excludes1 and Excludes2. What is the difference between the two types of Excludes notes and how do they relate to Excludes notes in ICD-9-CM?
When coders hear the words "interventional radiology," many think of vascular procedures. However, interventional radiology encompasses additional, nonvascular procedures, such as nephrostomy tube placement and drainage of abscesses.
Our coding experts answer your questions about physician supervision for chemotherapy, billing injectable drugs, Addendum B and coverage, new transitional care management codes, and stent placement with other procedures.
The AMA added five new nuclear medicine codes to the radiology section of the 2013 CPT Manual , while revising and deleting a number of codes that represented outdated technology or were bundled into placement procedures.
CMS defines self-administered drugs as drugs patients would normally take on their own. In general, Medicare will not pay for self-administered drugs during an outpatient encounter or for drugs considered integral to a procedure. Kimberly Anderwood Hoy, JD, CPC, and Valerie Rinkle, MPA, explain how to determine whether a drug is integral, self-administered, or both.
Q: The rule our institution has followed with respect to HCPCS coded medications without a local coverage determination (LCD) is to limit prescribing to the FDA-approved indications. The question that arises is how closely do the physicians need to follow the package insert? For example, the drug basiliximab does not have an LCD and the FDA indication is: For acute kidney transplant rejection prophylaxis when used as part of an immunosuppressive regimen that includes cyclosporine and corticosteroids. Generally, physicians performing transplants at our institution do not use steroids or cyclosporine. They use tacrolimus, sirolimus, mycophenolate mofetil, and/or mycophenolate sodium. If the physician performs a transplant without cyclosporine or steroids, do we need to have the patient sign an advanced beneficiary notice?
As more patients are being impacted by noncoverage of self-administered drugs, coders and billers need to know when and how to report drugs and drug administration services. Kimberly Anderwood Hoy, JD, CPC, and Valerie Rinkle, MPA, discuss the differences in how drugs are paid under Medicare Part A and Part B.
As part of the 2013 OPPS Final Rule, CMS made major changes to how it will reimburse facilities for separately payable drugs and how it will calculate APC relative weights. Jugna Shah, MPH, and Valerie Rinkle, MPA, review the most significant changes in the final rule.
Q: A patient went to the operating room under anesthesia for cataract extraction and repair of retinal detachment of the same eye. The surgeon successfully removed the cataract. The surgeon then accessed the back of the eye to begin to repair the detachment. After reviewing the condition of this eye area, the surgeon determined that the eye was in such bad shape it could not be saved, so the detachment was not repaired and surgery was ended. The patient was under anesthesia and the retinal detachment repair procedure was begun (although barely) but then cancelled. Should we report this procedure since the facility incurred expenses for the surgical attempt at repair?
One of the major changes to the 2013 CPT Manual is the replacement of the term "physician" with "physician or other qualified healthcare professional" (QHP) in a wide range of codes.
Physicians and other providers practice in many different areas within a hospital. To accurately code physician and provider services, coders must know and understand the place of service (POS) codes.
Q: How should we bill for the physician in the following situation? A patient who has end-stage renal disease (ESRD) comes into a hospital’s emergency department (ED) with an emergent condition (dialysis access clotted or chest pain that is ruled out), but misses his or her dialysis treatment. Part of the treatment is dialysis performed in the ED or as an outpatient. The hospital bills G0257 (unscheduled or emergency dialysis treatment for an ESRD patient in a hospital outpatient department that is not certified as an ESRD facility) as per CY 2003 OPPS Final Rule guidelines and Pub 100-04, Chapter 4, section 200.2
CMS announced changes to reporting therapy services—the biggest operational change for 2013—in the Medicare Physician Fee Schedule final rule instead of the OPPS final rule. Jugna Shah, MPH, and Valerie Rinkle, MPA, explain the changes to therapy reporting and molecular pathology coding.
Hospitals earned a big win with drug payments this year in the 2013 OPPS final rule, released November 1. CMS decided to finalize its proposal to follow the statute and reimburse facilities at the average sales price (ASP) plus 6%.
The biggest operational change for outpatient facilities for 2013 does not appear in the 2013 OPPS final rule. Instead, CMS announced changes to reporting therapy services in the 2013 Medicare Physician Fee Schedule (MPFS) final rule.
As part of the 2013 OPPS final rule, CMS finalized a clarification to 42 CFR 419.2(b) that could cause confusion in the future if hospitals are audited by third-party payers or by Medicare contractors who do not fully understand the intent of the language or how CMS develops payment rates, says Jugna Shah, MPH, president of Nimitt Consulting based in Washington, D.C.
As part of the 2013 OPPS final rule, CMS finalized a clarification to 42 CFR 419.2(b) concerning packaged services. Jugna Shah, MPH, and Valerie Rinkle, MPA, explain how this clarification could cause confusion in the future if hospitals are audited by third-party payers or by Medicare contractors who do not fully understand the intent of the language or how CMS develops payment rates.
Q: Is nursing documentation of completion of physician-ordered procedures, such as splinting/strapping, Foley catheter insertion, etc., sufficient to assign a CPT ® code for billing the procedure on the facility side in the ED?
Q: CPT ® code 85660 (sickling of RBC, reduction) has a medically unlikely edit of one unit. We test blood for transfusion for sickle cell before we provide it to a sickle cell patient. If we test three units of blood prior to administering the blood to the patient, which modifier is more appropriate: -59 (distinct procedural service) or -91 (repeat laboratory test)?
Our coding experts answer your questions about observation orders, sequencing additional diagnoses, coding for wound care with no-cost skin substitute, and reporting cardiac rehabilitation and physical therapy together.