Radiology Coding Alert

Freestanding radiation oncology centers that perform physics consultations (77336-77370) for skilled nursing facility (SNF) patients may unfortunately have to write off many of these services, thanks to the prospective payment systems billing mechanism. SNFs often transfer patients to the hospital for procedures that the SNF personnel cannot perform on-site, such as physicist evaluations. The CMS Skilled Nursing Facility Manual requires that SNFs arrange with hospitals to directly collect reimbursement for services that the SNF does not provide. Section 201.2 states, "To participate in the program, an SNF must have a written transfer agreement with one or more participating hospitals providing for the transfer of patients between the hospital and the SNF." Because both the SNF and the hospital operate under a prospective payment system (PPS), the financial agreement usually works smoothly. If, however, the SNF patient is instead transferred to a freestanding radiation oncology center (which does not operate under PPS), Medicare will not reimburse the technical components of services that may be provided at
that location.

Because both CPT 77336 (Continuing medical physicsconsultation, including assessment of treatmentparameters, quality assurance of dose delivery, and reviewof patient treatment documentation in support of theradiation oncologist, reported per week of therapy) and77370 (Special medical radiation physics consultation)are technical services only codes, freestanding centersare stuck without any way to recoup Medicarereimbursement for these services.

Although some freestanding centers have tried tonegotiate an arrangement with the SNF to pay for thetechnical service, this normally wont work because the SNF cannot recover the technical reimbursement from Medicare, either, says Cindy C. Parman, CPC, CPC-H, RCC, co-owner of Coding Strategies Inc., a medical reimbursement consulting firm in Dallas, Ga.

A private center that I recently visited received a refund request for thousands of dollars for all technical services it furnished to half a dozen SNF Medicare patients, Parman says. This is happening nationwide, and some carriers are a little slower than others to stop these payments, but be aware that it is on its way.