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June 2010 EditionHot Topics:AMA Coding Guidance:General Coding News:Hot Topics:Announcing the New CCH Health Reform ToolkitIn response to the new health reform laws—Patient Protection and Affordable Care Act and Health Care and Education Reconciliation Act of 2010—Wolters Kluwer introduces the CCH Health Reform Toolkit, a complete suite of electronic workflow tools for navigating and understanding the near 3000 pages of legislation into easy to understand topics related to the hospital, pharmaceutical, and legal industries. The Toolkit will further keep you abreast of all future Health Reform impact by automatically tracking related amended regulations, rules, new legislation, and primary source documents, providing access to full text documents and weekly email notifications so that you can keep on top of all guidance and changes that the government agencies release. Features include: easy to navigate topics; search topics using synonyms; plain English summary of law section with links to fully explanatory analysis; links to full text of enacted law, and amended law in place to reflect Health Reform in ERISA, IRC, and SSA; export all results in Excel, Word, or Email; import action item effective dates for Health Reform Effective Date Lookup to Outlook Calendar creating automatic reminders and instructions for compliance; and customizable results show changes made to a topic to reflect new rules, regulations, legislation, and primary source documents during the last 10 days, 30 days, 90 days, and more… The suite of tools includes what we call Smart Charts for the following topics: Providers, Medicaid, Drugs and Devices, Law Lookup, Effective Date Lookup, Grants Management, Demonstration Projects and New Programs, and Comprehensive—containing every provision in the Health Reform laws. The CCH Health Reform Toolkit is available with links to the CCH Medicare and Medicaid Guide laws, regulations and explanations, incorporating in industry trusted content with new workflow tools; or as a stand-alone product incorporating in the e-version of the CCH Law, Explanation & Analysis book on these health reform laws. To learn more about the CCH Health Reform Toolkit, please go to http://health.cch.com/Products/Health-Reform-Toolkit.asp; or contact your local sales rep at 888-224-7377. Are you Prepared for OPR Coverage?By Robin Miller Zweifel, BS, MT (ASCP)Finally after much anticipation the final rule for Medicare’s coverage of outpatient pulmonary rehabilitation has been released. Gone is the speculation that Medicare would provide separate payment options for education / education materials, supplies, devices, etc., in addition to the payment for outpatient pulmonary rehabilitation (OPR) services. According to CMS transmittals 124 and 1966 (both issued May 7, 2010), which describe the basic rules and national coverage guidelines for OPR, a single HCPCS now describes the billable service. G0424 Pulmonary rehabilitation, including exercise (includes monitoring), per hour, per session Beginning January 1, 2010, the HCPCS G0424 is reportable with a maximum of 2 billable units of service per day. However, as is typical for the CMS code definitions which are based on time there are very specific requirements for recording of the time increments in order to justify a billable “per hour, per session” unit of service.
In addition to exercises for strength and endurance, each session must include some aerobic exercise. Documentation of each form of exercise as well as the start and stop time for each will be integral to ensuring accurate billing and payment of services. Under the Medicare Part B physician standard for pulmonary rehabilitation services the supervising physician is responsible and accountable for the pulmonary rehabilitation program, including oversight of the department staff. He or she must be “substantially involved” in the program providing consultation with staff and direct patient contact with regard to the patient’s treatment plan. The supervision must be provided by a physician with “expertise in the management of individuals with respiratory pathophysiology, and cardiopulmonary training and/or certification including basic life support” and they must be licensed to practice within the State where the program is offered. Regardless of the setting – physician clinic or outpatient hospital department – the supervising physician and department personnel must be able to adequately respond to an emergent situation. All equipment necessary for treatment or diagnosis during an emergency or life-threatening event (oxygen, cardiopulmonary resuscitation equipment, and defibrillator) must be available within the area. Additionally, the new guidelines stipulate that a “physician must be immediately available and accessible for medical consultations and emergencies at all times when services are being provided under the program.” Unfortunately, CMS has once again not defined the term “immediate”, but provides example of the lack of immediate response as a physician who is performing another procedure or service that he or she could not interrupt in order to respond to an emergency – or – limiting their ability to intervene right away by being physically located on-campus at a distance far away from the rehabilitation area. For a full definition of “direct supervision of a physician” in the office setting refer to 42 CFR §410.26 which states the provision is satisfied if the responding / supervising physician meets the requirements for direct supervision which are defined in 42 CFR 410.32(b)(3)(ii). The definition of “direct supervision of a physician” differs slightly for hospital outpatient services. When the rehabilitation program is provided in a provider-based department of the hospital refer to 42 CFR §410.27 which stipulates the physician (doctor of medicine or osteopathy) be present on the same campus (not in the same room) where the service is provided and immediately available. Note that CMS decided not to enforce the requirements for direct supervision of therapeutic services that are furnished to outpatients in critical access hospitals (CAHs) during calendar year 2010. Refer to 42 CFR § 410.47 Pulmonary rehabilitation program: Conditions for coverage, for a full description of the nationally covered program and the required components. Multiple updates with regard to outpatient pulmonary rehabilitation services have been added to the Medicare manuals via CMS transmittals including inserts to the Medicare Benefit Policy Manual (BPM), Pub. 100-02, chapter 6 and chapter 15, as well as the Medicare Claims Processing Manual (CPM), Pub. 100-04, chapter 32, which provides detailed policy and claims processing instructions. CMS Announces Mid-Year Opportunity to Change Participation StatusBy Jennifer Ridell, CPC The recent passage of the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 included a 2.2 percent update to the Medicare Physician Fee Schedule. The Centers for Medicare & Medicaid Services (CMS) is offering physicians and other practitioners the chance to become participating. If you choose to change you participation status this will be reflected on all claims submitted after your new status is processed, claims previously submitted will not be adjusted to reflect your new participation status. Physicians and other practitioners whose current status is non-participating are eligible to apply for a change in status to participating through July 16, 2010. To apply, download and complete Form CMS-460 which is available at http://www.cms.gov/cmsforms/downloads/cms460.pdf and submit the form to your carrier. This form should not be submitted to CMS, it will result in a delay of processing. AMA Coding Guidance:Special Bulletin on ICD-10 TransitionBy Jennifer Ridell, CPC The American Medical Association (AMA) has released a Special Bulletin providing a detailed explanation of the transition from ICD-9 to ICD-10. This information covers general history of the ICD-9 and ICD-10 code set, recommendations for preparing different aspects of facility for the transition, and a comparison of the structure of ICD-9 vs. ICD-10 codes. The AMA has recommendations for what a practice/facility should be doing to prepare for the transition. These include:
To see the full Bulletin from the AMA, search for any ICD-9 code in CCH Coding Comply and click on the related documents link, there will be a reference to this bulletin that will allow you to see the extended information. May 2010 CPT AssistantBy Jennifer Ridell, CPC Allergy Testing (Code 95004, 95024, 95027) and E/M Reporting A physician may order allergy testing when allergies are suspected as being the cause of a patient's symptoms. The CPT codes used to report allergy testing are 95004 (percutaneous), 95024 (intracutaneous), and 95027 (intracutaneous). These codes include performing the test and the physician interpretation of test results along with preparation of a report of the results. If a separate significantly identifiable E/M service is reported on the same day as allergy testing, Modifier 25 must be appended to the separate E/M service code. Coding Communication: Myocardial Perfusion Imaging Changes were made to the myocardial perfusion imaging codes in the 2010 CPT code book. Specifically, CPT codes 78460-78465, 78478, and 78480 were deleted and replaced with new CPT codes 78451-78454. These new codes now include the wall motion and ejection fraction procedures in the base procedure code. The stand alone wall motion and ejection fraction codes, 78478 and 78480 were deleted from CPT 2010 and a parenthetical note was added instructing the use of the new codes. The new codes use the phrase "when performed" so these codes should be used even if no wall motion or ejection fraction was performed. CPT codes 78472, 78473, 78481, and 78483 should not be reported in conjunction with new CPT codes 78451-78454. Coding Brief: Infant Pulmonary Function Testing Recent advancements in pulmonary function tests now allow for adult type tests to be used to calculate complete fractional lung volumes in infants. CPT 2010 included three new codes to be used in reporting these procedures since they include increased work and time. The new codes are 94011-94013. CPT code 94011, measurement of spirometric forced expiratory flows in an infant or child through 2 years of age, is considered an inclusive component of code 94012, measurement of spirometric forced expiratory flows, before and after bronchodilator, in an infant or child through 2 years of age, and should never be reported with 94012. Code 94013, measurement of lung volumes (ie, functional residual capacity [FRC], forced vital capacity [FVC], and expiratory reserve volume [ERV]) in an infant or child through 2 years of age, can be reported with either 94011 or 94012 and can be reported twice on the same day. These new codes all include moderate sedation. Coding Clarification: Infusion/Injection Services The American Medical Association is further clarifying an answer they published in February 2009 to the question: On the basis of the infusion guidelines for facilities, in the following scenario, is IV hydration primary to an IV push in the hierarchy? A patient receives an IV hydration from 1:00 PM to 3:00 PM and two IV pushes of the same drug at 1:30 PM and 3:30 PM. This additional information includes further guidance on CPT codes 96360, 96361, 96365, 96368, 96374, 96376, 96409, and 96413. Coding Consultation: Questions and Answers An article by the CPT Editorial Panel answers questions posed to the panel regarding the subjects of surgery/musculoskeletal and female genital system, medicine/hydration, therapeutic, prophylactic, diagnostic injections and infusions, physical medicine and rehabilitation and neurology and neuromuscular procedures, radiology/diagnostic ultrasound and diagnostic radiology (diagnostic imaging), and modifiers. The responses answer multiple questions including: is it appropriate to report CPT code 95869, Needle electromyography; thoracic paraspinal muscles (excluding T1 or T12), for each level of the thoracic spine, and is it appropriate to report codes 97110-97124, if the procedure were performed at the same region as Chiropractic Manipulative Treatment (CMT)? To view these articles via CCH Coding Comply, search from the Search Code Sets tab in Coding Comply for any of the codes listed above, view the Related Documents by clicking on the paper icon next to the code, then select the article. To view these articles in The Coding Suite, go to the CPT Assistant Archives folder and in the Search field within this folder and enter “May 2010.” General Coding NewsRevisions and re-issuance of audiology policies to clarify correct coding and billingIn an effort to clarify the correct coding and billing practices for audiological diagnostic tests, CMS is revising and re-issuing the policies related to these tests. Audiologists, nonphysician practitioners (NPP), physicians, and in some cases technicians, are required to perform audiology services. A technician can perform the parts of the service that do not require professional skills under the direct supervision of a physician. All claims for audiology services must be reported using the appropriate HCPCS code. This coding requirement is effective for claims submitted on or after April 1, 1998. Beginning January 1, 1999, the Medicare Physician Fee Schedule became the prospective payment system for audiology services provided in the office setting and for the associated professional services furnished in physician’s office and hospital outpatient settings. There may be reason to use a Professioanl Component (PC) and Technical Component (TC) split code when billing for audiology services provided outside the facility setting. The PC of a PC/TC split code can be billed by the audiologist, physician, or NPP who directly furnishes the service and the TC may be billed by the physician if a technician furnishes the services under the direct supervision of that physician. The global service (PC and TC) can be billed when the same audiologist, physician, or NPP provide the service. If there is no appropriate code to report an audiology test, CPT code 92700, unlisted otorhinolaryngological service or procedure, may be reported. Medicare Claims Processing Manual, Pub. 100-04, Transmittal No. 1975, May 28, 2010. This transmittal can be viewed on the IRN or IntelliConnect at ¶159,121 in the June 7, 2010, CCH Coding Comply What’s New newsletter; or on Rex via The Coding Suite in the CMS Transmittals and MLN Matters Articles folder under the titles “R1975CP Revisions and Re-issuance of Audiology Policies.” NOTE: To follow the MediRegs links above, you will need to be a subscriber to the Coding Suite of products and if prompted, enter your username and password. If you cannot remember your user name or password go to: http://wk.mediregs.com/login_fs.html and the system will let you request a reminder. For the Internet Research Network or IntelliConnect links, you will need to be a subscriber to the CCH Coding Comply. Requests for information about article submission and comments from readers are welcome and should be directed to at Nicole Stone at Nicole.Stone@wolterskluwer.com, Fax 847-267-2514. Customer service inquiries should be directed to 800-449-9525. CCH Coding Compliance Advisor is published monthly by CCH, a Wolters Kluwer business. ©2010 CCH. All rights reserved. No claim is made to original government works; however, the gathering, compilation, and arrangement of such materials, the historical, statutory and other notes and references, as well as commentary and materials in this Publication are subject to CCH copyright. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is published with the understanding that the publisher is not engaged in rendering legal, accounting or other professional service. If legal advice or other expert assistance is required, the services of a competent professional should be sought. For more information about the The Coding Suite or CCH Health Care Portfolio, please visit our online store at http://mediregs.com or http://health.cch.com. You are subscribed to CCH® NetNews, sponsored by CCH INCORPORATED. Click here to unsubscribe. To manage your newsletter preferences or subscribe, click here. To unsubscribe via postal mail, please contact us at: CCH, Attn: Business Compliance Marketing, 2700 Lake Cook Rd., Riverwoods, IL 60015. Please include the email address you have been contacted with. |
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