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Coding Corner: NCCI Policy Manual updates: Part 2



CPR’s “Coding Corner” focuses on coding, compliance, and documentation issues relating specifically to physician billing. This month’s tip comes from G. John Verhovshek, the managing editor for AAPC, a training and credentialing association for the business side of health care.

Each year, the Centers for Medicare and Medicaid Services (CMS) releases an updated version of the National Correct Coding Initiative (NCCI) Policy Manual. The annual updates reflect changes to the CPT® and HCPCS code sets, as well as new and revised coding guidelines. This month, we’ll discuss the most significant, recent updates to chapters 8-12 of the Policy Manual that affect coding, compliance and reimbursement for providers (last month, we did the same for chapters 1-7 of the Policy Manual).

Chapter VIII: Surgery: Endocrine, Nervous, Eye And Ocular Adnexa, And Auditory Systems CPT Codes 60000-69999

Revised guidelines clarify coverage for blepharoplasty:
  • CMS payment policy does not allow separate payment for a medically necessary blepharoptosis procedure (CPT codes 67901-67908) and medically necessary blepharoplasty procedure (CPT codes 15822, 15823) on an ipsilateral upper eyelid.
  • If a medically necessary blepharoptosis procedure and cosmetic blepharoplasty procedure are performed on an ipsilateral upper eyelid, the cosmetic blepharoplasty may be reported, but is not a Medicare covered benefit.
  • A physician may bypass NCCI edits that bundle the blepharoplasty codes 15822-15823 into blepharoptosis procedure codes 67901-67908 with an NCCI-associated modifier if:
  • the blepharoptosis procedure and the blepharoplasty procedure are performed on contralateral upper eyelids; or
  • with appropriate modifiers in accordance with Medicare policy if the blepharoplasty procedure is a cosmetic procedure.

New language stresses that collection of blood specimen is reported only in addition to lab services, or if blood collection is the only service provided:

CPT code 36591 describes “collection of blood specimen from a completely implantable venous access device.” CPT code 36592 describes “collection of blood specimen using an established central or peripheral venous catheter, not otherwise specified.” These codes shall not be reported with any service other than a laboratory service. That is, these codes may be reported if the only non-laboratory service performed is the collection of a blood specimen by one of these methods.

Similarly, irrigation of implanted venous access device for drug delivery may be reported only if it is the sole service provided:

CPT code 96523 describes “irrigation of implanted venous access device for drug delivery system.” This code may be reported only if no other service is reported for the patient encounter.

Chapter IX: Radiology Services CPT Codes 70000-79999

New instruction state that beginning in 2018, 77063 Screening digital breast tomosynthesis, bilateral (List separately in addition to code for primary procedure) may be reported with 77067 Screening mammography, bilateral (2-view study of each breast), including computer-aided detection (CAD) when performed. Previously, the service described by 77067 was reported using HCPCS code G0202, which is now deleted.

New guidelines clarify tumor imaging:

  • For tumor imaging by positron emission tomography (PET), report 78811-78816.
  • If a concurrent computed tomography (CT) scan is performed for attenuation correction and anatomical localization, report 78814-78816.
  • Do not report separately 78811-78816 for a CT scan for localization.
  • If the data set for the diagnostic CT is obtained concurrently on the same PET/CT integrated system where the CT portion of the study is co-registered with the PET images for the purpose of attenuation correction and anatomic localization, report the diagnostic CT using 78811-78813, and append an NCCI-associated modifier (e.g., modifier 59).
  • If a data set for the PET/CT for attenuation correction and anatomic localization and a separate data set for the diagnostic CT are obtained on separate pieces of equipment, report the diagnostic CT with codes 78811-78816 and append an NCCI-associated modifier.

New guidelines state that a single unit of service (UOS) for an isodose plan (77316-77318) includes dose calculations at multiple points (e.g., calculations for the craniocaudal position and mediolateral position are included in the same UOS).

Revised guidelines state that evaluation of an anatomic region and guidance for a needle placement procedure by the same radiologic modality on the same date of service may be reported separately only if the two procedures are performed in different anatomic regions.

The above guidelines regarding blood collection (36591, 36592) and irrigation of venous access device (96523) are repeated in this chapter, and several times throughout the Policy Manual.

Chapter X: Pathology/Laboratory Services CPT codes 80000-89999

New guidelines specify that to report G0452 Molecular pathology procedure; physician interpretation and report, the service must “require… the exercise of medical judgment. If the information could ordinarily be furnished by a nonphysician laboratory specialist, the service does not require the exercise of medical judgment.”

New instruction preempts redundant gene testing, stating, “A physician shall not additionally separately report testing for the same gene or genetic region by a different methodology (e.g., CPT codes 81105-81408, 81479, 88364-88377). CMS payment policy does not allow separate payment for multiple methods to test for the same analyte.”

Instruction is added to distinguish between bone marrow biopsy (88305) and bone biopsy (88307):

  • Bone marrow biopsy(ies) are typically performed with a Jamshidi needle yielding a cylindrical core of bone and marrow.
  • A bone biopsy is typically performed with a different instrument and yields a larger non-cylindrical bony specimen which may include some bone marrow.

Guidelines are added to specify that a single unit of service for 88264 Chromosome analysis; analyze 20-25 cells includes up to 25 karyotypes. Similarly, 88280 Chromosome analysis; additional karyotypes, each study includes all karyotypes determined, per evaluation of a separate tumor.

New text specifies that you may report a single unit of service, per day, for urine drug definitive testing HCPCS G0659.

Chapter XI: Evaluation and Management Services CPT Codes 90000 – 99999

New guidelines allow, “If one or more immunizations and a significant, separately identifiable evaluation and management (E&M) service are rendered by a physician on the same date of service, both the immunization administration code (e.g., CPT codes 90460– 90474) and the E&M code with modifier 25 appended may be reported. If the patient returns on another day solely to receive another immunization, only the immunization administration code shall be reported.”

A revised guideline now states that the same provider may not report 92507 (treatment of speech, language, voice...; individual) or 92508 (treatment of speech, language, voice...; group) on the day as 97127 (therapeutic interventions that focus on cognitive function...) or 97533 (sensory integrative techniques to enhance...). But, if different providers perform the two separate services on the same day, they may each report the services they performed, separately.

An existing guideline state, “Cardiac catheterization, percutaneous coronary artery interventional procedures (angioplasty, atherectomy, or stenting), and internal cardioversion include insertion of a needle and/or catheter, infusion, fluoroscopy and ECG rhythm strips (e.g., CPT codes 36000, 36140, 36160, 36200-36248, 36410, 96360-96376, 76000-76001, 93040-93042).” A new guideline further clarifies that cardiac catheterization, percutaneous coronary artery interventional procedures, and internal cardioversion also include ultrasound guidance (76942, 76998, 93318, or other ultrasound procedural codes).

Instruction is added for left heart catheterization with percutaneous transcatheter closure of a mitral valve paravalvular leak (93590). If a left heart catheterization by transapical puncture is additionally performed, you may report add-on code 93462. But, do not report if the left heart catheterization is performed by trans septal puncture.

In the context of 94640 (pressurized or non-pressurized inhalation treatment for acute airway obstruction...) guidelines specify “An episode of care begins when a patient arrives at a facility for treatment and terminates when the patient leaves the facility.” New text qualifies, “If the episode of care lasts more than one calendar day, only one unit of service of CPT code 94640 shall be reported for the entire episode of care.”

Chapter XII: Supplemental Services HCPCS Level II Codes A0000-V9999

New instructions require that urine drug definitive testing (HCPCS G0659) is reported “per day,” and may not be reported with more than one unit of service, per day.



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