62311 & 36620

eortega

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Help!! Mcre is denying 62311-59 against 36620 for a THA revision, does anyone know about 04-01-09 MCRE EDIT? my coding looks like this:

01215 -paid
62311-59 denied COB-15 (M80)
36620-paid

Thanks!
Erika.
 

jdrueppel

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Per NCCI edits effective 4/1/09 62311 is bundled into 36620 with a "0" indicator meaning over-ride is NOT allowed even with a modifier and therefore not separately payable.

Effective 4/1/09 many of the historically separately payable blocks have been bundled into 36620 and 36556. In addition, many chronic pain services have been bundled (for example 62311 is now bundled into 20552). Below is the CMS/NCCI link:
http://www.cms.hhs.gov/NationalCorrectCodInitEd/NCCIEP/list.asp#TopOfPage

Our group is considering contacting the ASA for assistance in understanding these rigid edits. Anyone else have any other info?

Julie, CPC
 
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eortega

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yes Julie, I contacted CMS NCCI DEPT. inquiring for written documentation supporting their policy & this is the e-mail communication I got:
1st e-mail:
Dear Ms. Ortega:



Thank you for your letter dated June 2, 2009 about the National Correct Coding Initiative (NCCI). The Centers for Medicare and Medicaid Services (CMS) owns the NCCI and makes all decisions about its contents. You inquire about NCCI edits bundling CPT code 62311 (lumbosacral nerve block) into CPT code 36620 (arterial catheterization).



The basis for these edits is that Medicare rules do not allow a physician performing a procedure to bill separately for anesthesia for the procedure or for post-procedure pain management. Nerve blocks may be utilized for either of these purposes. CMS decided to add edits to the NCCI to help enforce this policy by bundling all nerve block codes into all global surgery procedures. Most of these edits do not allow use of NCCI-associated modifiers. Prior to implementation of these edits, the edits were released for a sixty day review and comment period to over 100 national healthcare organizations including over ninety national medical/surgical societies as well as the American Society of Anesthesiologists. No organization objected to the edit about which you wrote.



CMS is reconsidering NCCI edits included in this group as issues are brought to our attention through correspondence on individual edits. We will discuss your concerns with CMS and respond as soon as possible when a decision is made.



For this NCCI edit issue and those in the future, please allow 30 days for a response on CMS’ decision about the issue. If CMS agrees to change the modifier indicator on this edit to allow NCCI-associated modifiers to be used to report both procedures, then the earliest this change can be made is October 1, 2009. CMS reserves the right to make any changes retroactive to the implementation date of the edits. Providers may choose to delay submitting claims for nerve blocks performed on the same date of service as procedure 36620 until October 1, 2009. If CMS decides to change the edit, any claims denied based on these edits may be resubmitted or appealed after October 1, 2009.



Thank you.

Coding Specialist
National Correct Coding Initiative
Correct Coding Solutions, LLC
P.O. Box 907
Carmel, IN 46082-0907
Fax - 317-571-1745


MY REPLY:
Ms. Dietz:

Thanks for your response to my letter, your reference to CMS edits regarding pain management and anesthesia services not allowed by physician performing the procedure does not address my inquiry regarding the bundling policy for 36620 vs 62311, these are two totally different procedures that have always been paid without problem until 04-01-09, can you please direct me to where this new policy is written on CMS NCCI? I understand that
"The basis for these edits is that Medicare rules do not allow a physician performing a procedure to bill separately for anesthesia for the procedure or for post-procedure pain management. Nerve blocks may be utilized for either of these purposes. CMS decided to add edits to the NCCI to help enforce this policy by bundling all nerve block codes into all global surgery procedures. Most of these edits do not allow use of NCCI-associated modifiers." but this excerpt does not contain information about my inquiry.

I would appreciate propper direction towards this policy,
Thanks.

Erika Ortega, CPC


2nd e-mail:
Dear Ms. Ortega:



Thank you for your follow-up questions. I gave you the rationale for the edits as they were proposed to the national healthcare organizations and national specialty societies who perform these procedures prior to implementation of these edits. No objections were received on this NCCI edit prior to its implementation. The rationale for the edits is NOT included as instruction from CMS in its Internet-Only Manuals. The rationale was applied to all global surgery

procedures which includes CPT code 36620. The edits were added on April 1st when you noticed a change. Quarterly version updates to the NCCI edits convey the new edits to the provider community since they are posted on CMS’ website. In our annual update of the National Correct Coding Initiative Policy Manual for Medicare Services which occurs in the summer prior to implementation on October 1st, we include policy statements about NCCI edits added within the last year.

There is nothing written about this policy currently but through CMS’ established review and comment process we have informed many providers who are members of the national organizations who perform these procedures.



As I stated, CMS is reconsidering the modifier indicators on some of these NCCI edits. We have referred your letter to the Centers for Medicare and Medicaid Services (CMS) for further discussion and possible modification of this NCCI edit. We will respond to you as soon as a decision is made by CMS.

Please allow 30 days for this decision to occur since it depends on the scheduling of teleconferences with CMS Central Office Medical Officers in Baltimore.



We will send you a response as soon as a decision is made.





Coding Specialist
National Correct Coding Initiative
Correct Coding Solutions, LLC
P.O. Box 907
Carmel, IN 46082-0907
Fax - 317-571-1745
 
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jdrueppel

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WOW - choder! Fabulous job. It looks like you have done the leg work for all of us. Thank you. Please post any further responses you receive.

Julie, CPC
 

eortega

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Hi Julie, I just received a letter from NCCI stating that they're gonna delete this edit & will appear on NCCI version 15.3 scheduled for Oct 1st 2009, claims denies on this edit may be resubmitted for adjudication after 10/01/09.
yeey!!
Erika.
 

jdrueppel

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Does your letter address any of the other rigid edits effective 4/1/09 i.e. 64421 is inclusive of 36620 or is your letter specific to 36620/62311?

Julie, CPC

P.S. You're AWESOME :)
 
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eortega

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actually it only talks about 36620/62311, but I can fax you a copy of the letter & we can do the same inquiry with these other strange edits, Thanks also for your help in my other questions!

Erika.
 

eortega

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93503,36556 & 36620 vs 62310-62319 & 64400-64530

Julie, I just wrote another letter regarding the rest of the 04/01/09 edits for 93503,36556 & 36620, and I got a quick response from NCCI stating that MCRE already decided to delete these edits too, and claim resubmission for adjudication will also apply starting 10/01/09.

:DErika.
 

jdrueppel

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Erika,

Oh my God .....you're my new bestfriend :)

I'm sending you a private message with my fax number. Please send me copies of whatever you can.

Julie, CPC
 
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