Practice Management Alert

CCI:

Don't Rely on Modifier 59 Alone to Bypass CCI Edits, CMS Says

Key: Get to know modifiers 24 and 57 better.

You’ve heard the Correct Coding Initiative (CCI) mantra: If the CCI bundle has a modifier indicator of "1," you can separate the bundle using modifier 59 "or another suitable modifier." Have you ever wondered what the other "suitable modifiers" really are?

CMS now adds to the list of applicable modifiers, with the introduction of four more modifiers that Medicare contactors will accept to bypass CCI edits.

Review the Rule of Thumb

When a CCI coding combination is listed as either a mutually exclusive or comprehensive/component edit, the general rule is that both codes cannot be reported separately. However, two CCI indicators are commonly used to indicate when you can, in fact, report the procedures together under circumstances. An indicator of "0" indicates that it is never acceptable to bill these procedures together, and an indicator of "1" indicates that these codes are considered bundled but can be billed separately under certain circumstances, such as a separate site, separate incision, or separate injury.

Most coders who are trying to separate CCI edits will use either modifier 25 (Significant, separately identifiable evaluation and management service by the same physician on the same day of the procedure or other service) for edits involving E/M codes, or modifier 59 (Distinct procedural service) for bundles that involve two procedures. However, coding experts have long maintained that modifier 59 should be the modifier "of last resort," making many coders reluctant to use it extensively.

Take a Look at CMS’s Modifier List

CMS Transmittal 1136, released on Nov. 1, announces that you’ll be able to use the following modifiers to override a CCI edit with a modifier indicator of "1" effective Jan. 1, 2013:

  • LM (Left main coronary artery)
  • RI (Ramus intermedius)
  • 24 (Unrelated evaluation and management service by the same physician during a postoperative period)
  • 57 (Decision for surgery).

"This is good news because the main modifier used to bypass CCI edits was 59," says Laureen Jandroep, CPC, CPC-I, CMSCS, CHCI, senior instructor at CodingCertification.org in Oceanville, NJ. "Now it will be more granular."

Whereas modifiers LM and RI will mainly be used by heart surgeons, the other two modifiers are quite familiar to most other coders.

"LM and RI are mainly used by cardiologists," Jandroep says. "The percutaneous coronary intervention (PCI) procedures are re-worked for 2013 and these vessels are mentioned by name whereas previously we only had RC, LD, and LC modifiers."

Both modifiers 24 and 57 can be appended to E/M codes when the E/M service is either unrelated to a surgery (modifier 24) or results in the decision to perform the bundled procedure (modifier 57).

Modifier 24: You should only append modifier 24 to an appropriate E/M code when an E/M service occurs during a postoperative global period for reasons unrelated to the original procedure, says Ruth Borrero, CUC, billing supervisor at Prohealth Care in Lake Success, N.Y.

Modifier 24 tells the payer that the provider is seeing the patient for a new problem. "The diagnosis code tells the story but payers want to have coders put the modifier on the claim to indicate this -- perhaps because of the way their edits/flag system is set up," Jandroep says.

When you report modifier 24, the E/M service must meet these criteria:

  • The E/M service occurs during the postoperative period of another procedure. 
  • The current E/M service is unrelated to the previous procedure.
  • The same physician (or tax ID) who performed the previous procedure provides the E/M.

Modifier 57: You might use modifier 57 (Decision for surgery) when your surgeon performs a procedure and a distinct E/M service for the same patient on the same day. "Modifier 57 is added to an E/M code the when decision for a major surgery with a 90-day global period was made," Borrero explains.

"Modifier 57 tells the story that even though there is an E/M and a surgery procedure on this claim form within a day of each other, the E/M is not a pre-op visit," Jandroep agrees. "It was the ‘decision for surgery’ visit and is therefore not bundled into the surgery code (package)."

Use modifier 57 if the claim meets all of the following criteria:

  • The E/M occurs on the same day of or the day before the surgical procedure
  • The E/M service directly prompted the surgeon’s decision to perform surgery
  • The surgical procedure following the E/M has a 90-day global period
  • The same surgeon (or another surgeon with the same tax ID) provided the E/M service and the surgical procedure.

Because modifier 57 claims involve an E/M service that results in a decision for surgery, you would expect to see the same diagnosis code for both the E/M and the surgical procedure. The surgeon would not make a decision for surgery based on a significant problem unrelated to the procedure.

Resource: To read the complete Transmittal, visit www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R1136OTN.pdf.