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.
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%.
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)?
The Hospital Outpatient Payment Panel recommended CMS change the supervision requirements for 15 HCPCS and CPT codes during its second meeting this year in August. CMS released details of the meeting September 24.
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.
Misusing modifier -25 (significant, separately identifiable E/M service by the same physician on the same day of the procedure or other service) can be an expensive proposition. Just ask Georgia Cancer Specialists I, a leading oncology practice in Atlanta.
Q: What CPT ® code best describes the Bier block procedure? We are toiling over this and the most recent CPT Assistant says to use 64999 (unlisted procedure, nervous system). But the article referenced is from 2004. We just want to make sure there is nothing more recent.
Our coding experts answer your questions about how to determine the correct units for drugs, billing for fluoroscopy, therapy caps under OPPS, and payment for critical care and separately reported services
Because of the increase in the number and type of outpatient services provided, more patients are being impacted by noncoverage of self-administered drugs. Kimberly Hoy, JD, CPC, and Valerie Rinkle, MPA, explain why CMS sometimes--but not always--covers self-administered drugs.
The rules for coding for facilities and physicians are basically the same for most services, but coders follow different rules for appending certain modifiers. Christi Sarasin, CCS, CCDS, CPC-H, FCS , Kimberly Anderwood Hoy, JD, CPC , and Peggy Blue, MPH, CPC, CCS-P, separate physician and facility rules for using modifiers -26, -TC, and -79.
Q: It appears that one requirement for using CPT ® codes 15002–15005 with application of negative pressure wound therapy (NPWT) is that the wound must be healing by primary intention. Can you explain this? We have never used these codes with preparation for vacuum assisted closure (VAC) placement, but it doesn't make sense, as NPWT is almost always used for wounds healing by secondary intention. Our physicians appreciate any clarification.
QUESTION: I work for a gastrointestinal (GI) practice and I have a question regarding the correct sequence for adding diagnosis codes to a claim. I have advised our physicians and billers that the primary diagnosis code is always the reason for the visit. I am a little confused about the remaining diagnosis codes the physician will write down in no specific order. Billers will report codes in the order the physicians write down the diagnoses and not always the reason for the visit. For example, a patient is referred for a consult due to weight loss. The patient comes for the consult and the physicians may put down 787.29 (other dysphagia), 401.1 (benign hypertension), 783.21 (abnormal loss of weight), 787.99 (change in bowel habits) in this order and leave it up to the person entering the info to figure it out. I would report 783.21 first since that was the reason for the visit but then I’ve been putting the GI codes next and then anything else last. What is the correct sequence when adding diagnosis codes to a claim?
Accurate reporting of observation services depends on a lot of factors. Deborah K. Hale, CCS, CCDS, and Cheryl Staley, RHIA, CCS, walk though five case studies to explain the ins and outs of observation coding.
CMS proposed extending the delay on enforcement of physician supervision rules for critical access hospitals and small and rural hospitals with 100 or fewer beds for one final year as part of the 2013 OPPS proposed rule. Debbie Mackaman, RHIA, CHCO, and Jugna Shah, MPH, detail some of the more significant proposals for 2013.
When the AMA revised the instructions for reporting ancillary services with critical care in 2011, facilities knew they wouldn't see an immediate increase in payment. CMS determines payment amounts through use of claims data from two years earlier, meaning the earliest facilities could expect additional reimbursement is 2013.
Our coding experts answer your questions about coding for hysteroscopy prior to ablation, appending modifier -59 for MRI and MRA, charging for venipunctures, therapy caps under OPPS, reporting limits for Provenge®, modifier -59 and infusion therapy, Reporting TEE pre- and post-operativley, coding for toxic metabolic encephalopathy
Inpatient-only procedures are those that CMS has determined providers must perform on an inpatient basis because they are invasive and require at least 24 hours of postoperative recovery time or monitoring.
QUESTION: I work in an urgent care setting and need to know if we can bill an administration code for injection of Toradol. For example, a patient comes in, and the provider performs an E/M and administers 60mg Toradol intramuscular. I have not been charging for it, thinking it’s bundled into the E/M.
CMS is proposing two major changes as part of the 2013 OPPS proposed rule, released July 6. One has to do with how CMS proposes to calculate APC relative weights; the other addresses the reimbursement level for separately payable drugs and biologicals without pass-through status. Jugna Shah, MPH, and Debbie Mackaman, RHIA, CHCO, discuss the proposed changes for OPPS payment.
Physicians and facilities use the same codes to report evaluation and management (E/M) levels for emergency department (ED) services, but follow different rules. Caral Edelberg, CPC, CPMA, CAC, CCS-P, CHC, and Raemarie Jimenez, CPC, CPMA, CPC-I, CANPC, CRHC, explain how to correctly choose the most appropriate E/M code for ED services.
Our coding experts answer questions about reporting dialysis for ESRD patient in ED, coding for sequential infusions, procedures on the inpatient-only list, replacement code for C9732, and new drug HCPCS codes.
CMS is proposing two major changes as part of the 2013 OPPS proposed rule, released July 6. One has to do with how CMS proposes to calculate APC relative weights; the other addresses the reimbursement level for separately payable drugs and biologicals without pass-through status.
Q. When is it appropriate to append modifier -74 (procedures discontinued after anesthesia administration or after the procedure has begun) or -73 (procedures discontinued prior to anesthesia) instead of to modifier -52 (reduced service)? Is there more than anesthesia that determines their use? The report below was coded with CPT ® 62311 (injection[s] of diagnostic or therapeutic substance[s]…; lumbar or sacral [caudal]). I asked the coder if modifier -74 should be appended, and the coder said that -52 should be appended. Is this correct? Procedure: Attempted lumbar midline interlaminar epidural steroid injection L5-S1 with fluoroscopy After identifying the L5-S1 interlaminar space fluoroscopically, the skin was sterilely prepped and draped. The skin and subcutaneous tissue were anesthetized with 1% lidocaine. Utilizing a loss of resistance technique and intermittent fluoroscopic guidance, an 18 gauge Tuohy needle was utilized to approach the epidural space. I was not able to successfully identify the epidural space secondary to encountered resistance. The needle depth was checked on lateral views and noted to be superficial to the epidural space when resistance was encountered. We were going to utilize a caudal approach, however skin breakdown was noted. At this point, I elected to have her return for care in 2 weeks and get the skin breakdown in the caudal area treated.
Some wounds and conditions don’t respond to conventional therapies and treatment modalities. In those cases, providers may consider hyperbaric oxygen therapy (HBO). Gloria Miller CPC, CPMA, and Todd Sommer, DO, DPM, CWS, review the conditions eligible for HBO therapy and correct code assignment for these services.
QUESTION: A patient complained of intractable pain from compression fracture (sustained the day prior to admission). The guidelines state if pain is not documented as acute or chronic, don't assign codes from the 338 category. Should we query the physician if the pain was acute or chronic rather than just using the fracture code if it appears that pain control was the main reason for the visit?
As part of the July update to the Intergrated Outpatient Code Editor, CMS reinstated HCPCS C1882 to the list of acceptable devices for CPT code 33249. Dave Fee, MBA, explains the implications of the change and reviews code changes included in the update.
Physicians can perform three different types of wound debridement and coders will find different codes for each type. Gloria Miller, CPC, CPMA, and John David Rosdeutscher, MD, discuss the different types of debridement, as well as coding and documentation requirements.
HCPCS code C1882 (cardioverter-defibrillator, other than single or dual chamber [implantable]) will once again meet the criteria to override the device-to-procedure edit for CPT® code 33249 (insertion or replacement of permanent pacing cardioverter-defibrillator system with transvenous lead[s], single or dual chamber).
Coders can run into two types of edits that may require them to append modifier -59 (distinct procedural service) to override: NCCI edits and medically unlikely edits (MUE).
Coding for physician services doesn’t always match coding for facility services, which can cause problems for coders who code records for both. ED E/M is one area where different rules come into play.
In this month's issue, our coding experts answer questions about how to differentiate between modifiers -52, -73, -74, coding for negative pressure wound therapy, and billing the technical component of pathology services.
Coders can run into two types of edits that may require them to append modifier -59 (distinct procedural service) to override: National Correct Coding Initiative (NCCI) edits and medically unlikely edits (MUE). Sarah L. Goodman, MBA, CHCAF, CPC-H, CCP, FCS, and Susan E. Garrison, CHCA, CHCAS, CCS-P, CHC, PCS, FCS, CPAR, CPC, CPC-H, explain the differences between the edits and how to correctly determine when to override the edit.
QUESTION: Our laboratory medical director sent out a notification to our medical staff, patient care departments, and order entry personnel that a physician order that read “CBC” or “CBC with differential” would be completed as a CBC with automated or manual differential and coded using CPT ® code 85025 (blood count; complete [CBC], automated [Hgb, Hct, RBC, WBC, and platelet count] and automated differential WBC count). Should we code 85025 when the order just reads CBC and when we do a manual differential with the CBC?
An anesthesia provider faces plenty of challenges: cancelled anesthesia, failed medical direction, monitored anesthesia care, time issues, invasive line placement rules, and start/stop times. Judy A. Wilson, CPC, CPC-H, CPCO, CPC-P, CANPC, CPC-I, CMRS, reviews some of the common challenges coders face when reporting anesthesia services.
Our coding experts answer your questions about correct use of modifier –PD, coding infusions to correct low potassium levels, payment for HCPCS code J2354, appropriate reporting of IV push followed by infusion of the same drug, and the difference between modifiers –AS and -80.
A physician can debride a wound to remove dead, damaged, or infected tissue so the remaining healthy tissue can better heal. Coders need to look for specific information in the documentation of wound debridement.
QUESTION: The vendor for our cochlear implants has stated it’s standard to provide our operating suite with the cochlear device and two external speech processors. Should we report HCPCS Level II code L8614 (cochlear device, includes all internal and external components) for the one device and two external speech processors even though one processor is sent home with the patient? If so this means that we should charge the patient for the device and two processors as one price under revenue code 278.
Emergency Departments (EDs) see a wide range of illnesses and injuries, from minor to major, which may require critical care. Lois E. Mazza, CPC, details how critical care is defined, what elements providers must document, and under what circumstances critical care can be coded for ED patients.
Chronic kidney disease (CKD) is the permanent alteration in the kidney’s ability to perform filtration and reabsorption functions. Patients with CKD can come into an outpatient clinic or may be admitted as an inpatient, either for the CKD or some other condition. Debra Lawson, CPC, PCS, and Jennifer E. Avery, CCS, CPC-H, CPC, CPC-I, explain the ICD-9-CM and CPT ® coding for CKD.
An absence of start and stop times is one of the more frequent challenges that coders face when reporting injections and infusions. Denise Williams, RN, CPC-H, and Jugna Shah, MPH, highlight some other challenges to help coders determine how to code for injections and infusions.
