Several edits were implemented January 1, 2020 which have caused many radiology providers angst with unexpected denials. The extent of the impact depends upon the type of organization (imaging center versus hospital) and the provided services. These challenges are a good reminder of why new edits must be reviewed every quarter to identify potential areas of financial impact.
First let’s discuss the nuclear medicine edits. The Correct Coding Initiative (CCI) edits have always bundled a long list of radiopharmaceutical codes into the bone imaging codes (78300-78315). This list has recently been expanded to include more codes such as:
- A9503 (Technetium tc-99m medronate, diagnostic, per study dose, up to 30 millicuries)
- A9524 (Iodine I-131 iodinated serum albumin, diagnostic, per 5 millicuries)
- A9561 (Technetium tc-99m oxidronate, diagnostic, per study dose, up to 30 millicuries)
You can find the complete list at:
https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/NCCI-Coding-Edits.
The biggest challenge is that the new edits do not allow the A codes to be billed on the same date of service as the imaging study. At this time, the Society of Nuclear Medicine and Molecular Imaging (SNMMI) has confirmed at least some of these new CCI edits are errors. The SNMMI is working with Centers for Medicare and Medicaid Services (CMS) officials, the CCI contractor and the American Medical Association (AMA) to alert providers of identified errors. As SNMMI works to identify all potential errors, SNMMI recommends to continue billing as usual. Although payment for the radiopharmaceutical will currently be denied, providers should bill the radiopharmaceutical so they may be correctly reimbursed when the CCI edits are corrected.
The second big edit issue is the bundling of the modified barium swallow exam (74230) into the speech language pathology service (92611) when both are performed at the same encounter. The CCI modifier indicator for this code pair is 0, meaning it cannot be bypassed using a modifier. This is problematic for health care facilities billing for both services.
According to CPT® Assistant (July 2014), code 74230 represents the radiological supervision and interpretation (S&I) service associated with code 92611, which is a “clinical, observational procedure.” The CPT® Manual instructs to report 74230 for the radiological supervision and interpretation. However, CCI edits supersede CPT® guidance for Medicare and any other payers that follow the CCI edits.
On February 3, 2020, the American Speech-Language-Hearing Association (ASHA) announced CMS is reversing the CCI edit retroactive January 1, 2020, and the edit will be corrected in the CCI files as soon as possible. This correction will allow health care facilities to appropriately bill for their services.
CMS also stated that billing codes 92611 and 74230 on the same day required a modifier to indicate the services are separate and distinct. Therefore, the swallowing study is correctly reported as 92611 listed first, followed by 74230-59. Once the CMS has made the correction, all claims submitted since January 1 that correctly list 92611 and 74230 may be resubmitted for payment of code 74230 with the addition of modifier 59.
Melody W. Mulaik, MSHS, CRA, RCC, RCC-IR, CPC, COC, FAHRA, is the president of Revenue Cycle and Coding Strategies Inc.
