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.
