Question ASC BILLING POST-OPERATIVE PAIN BLOCK

AnitaC

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Trying to get some input so, I have now posted this in three locations. 60+ views but no comments?! Can someone please assist me?

My question is more for the ASC billing the post-operative block done in a pre-operative holding area billing for the technical portion. The surgeon request the block. The anesthesiologist does the block and bills the global fee. No TC/PC modifier billed. Since professional NCCI edits apply to my ASC facility bill, wouldn't the ASC portion be denied? This is what I am thinking per edits. It is the same facility provider that provided the facility for the surgery. There is not a second “provider”, so the override is not allowed.

Am I off base here? Wouldn't that be similar to "double dipping"?

Thank you for your input!!
 

thomas7331

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I have not worked on the ASC side, but this same question has also come up in the hospitals where I have worked and in my experience is a bit controversial.

First of all, there is no global/TC/PC breakdown for nerve blocks - those codes have a site of service differential, just as surgical codes do. The anesthesiologist would bill the procedure with an ASC POS code on the professional claim with no modifier and would be paid the professional fee only based on the ASC location. So there is no issue with how the anesthesiologist bills that should affect the facility billing and it is not 'double dipping'.

As far as the facility fee, yes there are NCCI edits for the facility which are based on the guidelines described in the NCCI manual which state that anesthesia by the surgeon is never separately paid, but this edit can be bypassed with a modifier. One facility I worked with interpreted this to mean that if the block was placed by a physician other than the surgeon, then a modifier was appropriate, and XP was used to indicate this. But another facility interpreted the regulations to imply that in order to meet the requirements to bill for a physician of a different specialty to perform the nerve block, the surgeon would need to document the order and the medical necessity of this in the patient's record, and since this was rarely done, the facility elected not to charge separately for those nerve blocks done by the anesthesiologists.

I'm not sure what is ultimately the right answer to this question, and I'm not aware as to whether or not CMS or any other payers have issued in written guidance on this with regard to facility billing and coding. What I can tell you, though, is that for outpatient hospital claims under OPPS reimbursement, the nerve block code is packaged into the APC payment rate for almost every surgical procedure, so although the modifier does resolve the NCCI edit, billing for the nerve block does not change the final payment at all. You might wish to research whether or not this is the case for ASC payment as well, and also review your facility's payer contracts and reimbursement policies for guidance, because it could be a moot point.
 
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AnitaC

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Thank you for replying. Yes, OPPS has this as a status N I believe. I know CMS also bundles on the ASC side, pretty sure. My thought is that if the ASC billed it would be considered as included for the facility as included in the surgical facility fee per NCCI edits. Having nothing to do with the providers themselves. I do know the anesthesiologists get paid regardless. Hopefully, I will get a reply from an ASC. Again, thank you so much for taking the time to reply. I do appreciate it!
 
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