Oncology & Hematology Coding Alert

Question: We're having a debate about whether we may report the professional component of 77334 for IMRT patients. Is there any authoritative guidance?

Texas Subscriber

Answer: You typically should not report device codes 77332-77334 (Treatment devices, design and construction ...) in addition to IMRT planning (77301, Intensity modulated radiotherapy plan, including dose-volume histograms for target and critical structure partial tolerance specifications).

TrailBlazer, the Medicare Administrative Contractor (MAC) for Texas, has a local coverage determination (LCD) stating you must prove medical necessity to code both:

"Medicare would not expect to see providers billing frequently for the design and construction of devices that are separate and distinct from the 'device' derived from the computerized IMRT plan. The Correct Coding Initiative (CCI) bundles the device codes 77332-77334 into 77301. In cases where these separate devices are billed, the medical record must clearly demonstrate the medical necessity and rationale for the service" ("Intensity-Modulated Radiation Therapy (IMRT)," 4R-22AB, available at  www.trailblazerhealth.com).

Another example: Noridian Medicare, carrier for several Western states,clarified that its providers may report both when "a provider designs and constructs a treatment device separate and distinct from the one derived from the computerized IMRT plan."

Remember to append modifier 59 (Distinct procedural service) -- but only if the medical record has documentation to support modifier 59 use. The clarification warns that you should not report IMRT planning and treatment device codes on separate days simply to avoid the bundle. (Locate the article "IMRT Plan 77301:NCCI Edit Clarification" by searching for document ID "A39731" at www.cms.hhs.gov/mcd/search.asp).

Caution: You will find specialty societies that recommend reporting IMRT planning and devices together, but remember to use a payer's written policy as the overarching guidance on how to code properly for that payer.

-- Technical and coding advice for You Be the Coder and Reader Questions provided by Kelly C. Loya, CPC-I, CPhT, senior consultant with Los Angeles-based Sinaiko Healthcare Consulting.