Cardiology Coding Alert

Here’s proof that sidestepping bundles is against the rules.

The 2017 update to the Correct Coding Initiative (CCI) manual is out, bringing plenty of changes marked in bright red in the new version. Here’s a quick tour of the updates of most interest to cardiology coders.

Don’t Use Scheduling to Game the System

An addition to Chapter I, Section A, falls under general correct coding policies, and that means it’s important for everyone to know.

The addition refers to MUEs, which are Medically Unlikely Edits. In short, MUEs give a maximum number of units expected for a service. The wording also refers to NCCI PTP edits, which stands for National Correct Coding Initiative Procedure-to-Procedure edits, sometimes called column 1/column 2 edits.

Here’s the new wording: “MUE and NCCI PTP edits are based on services provided by the same physician to the same beneficiary on the same date of service. Physicians should not inconvenience beneficiaries nor increase risks to beneficiaries by performing services on different dates of service to avoid MUE or NCCI PTP edits.”

This rule shouldn’t be a new concept for you, but if you ever need support to show your team that CMS has specifically addressed this type of scheduling, now you know where to go.

Term tip: To get the full meaning of the addition, you need to remember that CMS sometimes uses words in unexpected ways. In this case, it’s important to know that the CCI manual generally uses “physician” to mean “all practitioners, hospitals, providers, or suppliers eligible to bill the relevant HCPCS/CPT^® codes.” You’ll find that explanation on page 4 of the manual’s Introduction Chapter. You also need to keep in mind that Medicare will consider all cardiologists in your group to be like a single physician for reporting purposes.

Bundle Access Site Repair Into Procedure

The addition of Chapter V, Section D.9, offers another refresher on proper coding: “Repair and closure of a blood vessel utilized for vascular access during the performance of a procedure is an included component of that procedure. Repair of the blood vessel (e.g., CPT® codes 35201-35286) should not be reported separately.”

A cardiologist is unlikely to provide a vessel repair procedure, but the rule is worth noting, especially if you also code for vascular physicians, so you won’t be tempted to report a repair code when CCI specifically forbids it.

Keep Medicare and CPT^® Rules Separated

Chapter XI, Section I. 14 describes coding percutaneous coronary intervention. The subsection isn’t new, but it adds some new language: “Medicare does not pay separately for PCI in a branch of a major coronary artery as this payment is included in the payment for the PCI code for the corresponding major coronary artery.”

This addition doesn’t change the previous rule or payment policy. The change helps clarify that even though CPT® provides codes in the 92920 to +92944 range for branch services and the manual discusses those codes, Medicare will not pay for them.