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.
