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.
