Oncology & Hematology Coding Alert

Question: If a radiation oncology practice owns a CT scanner, can the practice be reimbursed if it's used to help prepare simulations, even though they are not diagnostic?

New Mexico Subscriber 
 
Answer: If the radiation oncology practice owns the scanner, it can be paid for the technical component, that is, obtaining the CT images. Code 76370 (computerized tomography guidance for placement of radiation therapy fields) designates a treatment plan that includes a CT scan to localize the treatment portals. This means there are a limited number of CT slices obtained to localize the tumor area. The CT slices are generally not interpreted by a radiologist but are simply imported into the 3-D treatment- planning system.
 
In contrast, a diagnostic scan includes more slices and is performed to diagnose or "rule out" medical conditions. A field-placement scan is used to define the radiation fields when there is a tumor.
 
If you're billing for a freestanding center, you can report the technical component of the CT scan with 76370-TC (or however the payer wants you to report it). Because CT slices are generally obtained for use in a 3-D planning system, a separate interpretation and report is not performed, and, therefore, you cannot bill for the professional service (CPT Assistant, Fall 1991). However, it is necessary to have documentation in the patient chart that the treatment-planning CT was performed. Most payers will accept a brief dictation by the radiologist or radiation oncologist.
 
This documentation can include the number of slices obtained, the anatomic area, and the fact that the data were transferred to the treatment planning or simulation unit. Documentation doesn't generally meet the requirements for a professional interpretation, however, but simply verifies the completion of a treatment-planning CT.
 
If the CT equipment is on hospital premises, practices cannot bill for the technical component of the service unless it:
 
1. Owns or leases the equipment at fair-market value
 
2. Owns or leases the space at fair-market value and   

3. Employs the technician(s) in an arrangement that satisfies the IRS employer-employee relationship.
 
There are exceptions to these guidelines for joint ventures and similar arrangements, so you should consult healthcare counsel if the oncology practice is contemplating purchasing equipment for use in a hospital.