Primary Care Coding Alert

RHCs Should Break Down ECG, X-Ray Global Codes

Regardless of ZIP code list, use component codes or face denials

If your practice falls under the alphabet soup of an RHC, HPSA and/or a PSA, your ECG and x-ray service payment depends on submitting component codes.
 
The April 2005 Family Practice Coding Alert discussed ECG filing rules for family physician coders whose practices fall in a healthcare-professional or physician scarcity area (HPSA/PSA). The piece sparked numerous questions that our experts field below.

1. The ECG Reporting Rules Apply to RHCs

"I have been told that if your office is a Rural Health Clinic (RHC), you don't have to follow the HPSA and PSA ECG coding policies," says Ronda Tews, CPC, CCP, coding and compliance manager at St. John's Hospital in Springfield, Mo. "Can you verify this?" she asks.
 
Although an RHC won't receive diagnostic test bonus payment, you must still follow the same coding guidelines. "If you are an RHC, you must always file ECG and x-ray services with the component codes," says Ron L. Nelson, PA-C, president of Health Services Associates in Fremont, Mich.

2. Reimbursement Necessitates Component Billing

 HPSAs, PSAs and RHCs, however, must use diagnostic test component codes, but for different reasons.
 

  • Scarcity-area ECG bonus payment hinges on separate reporting. CMS will only pay the HPSA and PSA bonus on the professional component.
     
    Example: When a coder whose practice falls in an HPSA and/or PSA approved ZIP code reports a global ECG service, she must split out the services. For the technical component, she would use 93005 (Electrocardiogram, routine ECG with at least 12 leads; tracing only, without interpretation and report). She would report the professional component as 93010 (... interpretation and report only). The carrier will reimburse the professional component (93010) an extra 5, 10 or 15 percent, depending on the group's classification.
     
  • RHC reimbursement depends on service. In an RHC, the fiscal intermediary pays for Part A services, and the Medicare carrier covers Part B services. "The technical component of an ECG or x-ray service is a Part B service, and the professional component is an RHC service as long as an RHC physician or nonphysician practitioner performs the service," says Nelson, who is also the co-founder and first president of the National Association of Rural Health Clinics.
     
    Bottom line: An RHC coder must also break out diagnostic test services. For instance, you would report an RHC-performed ECG as 93005 (technical) to Part B and 93010 (professional) to the FI.

    3. RHC WTM Won't Net Additional Pay

    As an HPSA, PSA and/or RHC, you must also separately bill Welcome to Medicare ECG-related services. Instead of reporting the global code G0366 (Electrocardiogram, routine ECG with at least 12 leads; with interpretation and report, performed as a component of the initial preventive physical examination), you would report:
     

  • the technical ECG component as G0367 (... tracing only, without interpretation and report, performed as a component of the initial preventive physical examination)
     
  • and the professional component with G0368 (... interpretation and report only, performed as a component of the initial preventive physical examination).
     
    A coder in an HPSA or PSA would report both codes to the local Medicare carrier. An RHC coder would also file the technical claim (G0367) to Medicare but submit the professional portion (G0368) to the FI.
     
    Catch: Even though the RHC coder's FP could render services in an HPSA and/or in a PSA, the RHC will not receive the bonus on the ECG service. CMS only pays the bonus on the professional portion - the portion the RHC is filing to the FI.

    4. Modifiers Avoid X-Ray Denials

    Separating out the technical and professional components is also crucial for correct x-ray payment. But since x-ray codes don't have specific component numbers, "you need to use modifiers TC and 26," says Traci Schuller, CPC, coding coordinator at Community Health Care Clinics of King County (CHCKC) in Washington.
     
    In fact, if you omit the modifiers, the carrier will deny the charges. "Part B payment will be made only for the technical component (modifier TC) of global codes, or tests which are technical only by definition," states Medicare NHIC in its Riverbend GBS LMRP for RHCs.
     
    How it works: If an RHC using place of service 72 (Rural health clinic) bills for a chest x-ray (71020, Radiologic examination, chest, two views, frontal and lateral), the carrier will deny the service. The unmodified CPT code includes a professional component, which is part of the Part A RHC benefit payment. You should instead bill the service using 71020 with modifier TC (71020-TC, Technical component). The RHC would then report the professional component for the radiologist's reading as 71020-26 (Professional component).

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