Wiki Billing & documentation for CPT code 77336 - Continuing medical physics consultation

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medicalauditor

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I am auditing a dermatologist, and I have this scenario: The dermatologist (Dr. A) is billing CPT code 77401 for performing SRT, and Dr. A also bills CPT code 77336 for medical physics consultation. Both chart notes are signed off by Dr. A. I am assuming that the SRT was actually done by a radiation therapist but is billed under Dr. A as incident-to, however there is no documentation of who the radiation therapist is, or of the service being incident-to - the chart looks like Dr. A did the SRT and is signed off by Dr. A. Also, the chart note for the medical physics consultation states that the consultation is being provided "per the request of Dr. A" implying that someone other than Dr. A is actually doing the medical physics consult, but the note is signed off by Dr. A and also billed by Dr. A. There is no mention of the physicist who did the consult. I am not too familiar with oncology so would appreciate some help here. My first question is:
1. Considering that the 77336 code description states that the service is "in support of the radiation oncologist", can this be billed by the same provider who is doing the SRT? Even if the people doing the SRT and the med physics are 2 different people, can the 2 services be billed by the same provider?
2. Secondly, how should the 2 services be documented and who should be signing off on them?
3. Does 77336 even apply to SRTs?
4. Can you please provide a link to the CMS/Medicare resource which provides the guidelines and documentation requirements?
Thank you so much.
 
medicalauditor said:
I am auditing a dermatologist, and I have this scenario: The dermatologist (Dr. A) is billing CPT code 77401 for performing SRT, and Dr. A also bills CPT code 77336 for medical physics consultation. Both chart notes are signed off by Dr. A. I am assuming that the SRT was actually done by a radiation therapist but is billed under Dr. A as incident-to, however there is no documentation of who the radiation therapist is, or of the service being incident-to - the chart looks like Dr. A did the SRT and is signed off by Dr. A. Also, the chart note for the medical physics consultation states that the consultation is being provided "per the request of Dr. A" implying that someone other than Dr. A is actually doing the medical physics consult, but the note is signed off by Dr. A and also billed by Dr. A. There is no mention of the physicist who did the consult. I am not too familiar with oncology so would appreciate some help here. My first question is:
1. Considering that the 77336 code description states that the service is "in support of the radiation oncologist", can this be billed by the same provider who is doing the SRT? Even if the people doing the SRT and the med physics are 2 different people, can the 2 services be billed by the same provider?
2. Secondly, how should the 2 services be documented and who should be signing off on them?
3. Does 77336 even apply to SRTs?
4. Can you please provide a link to the CMS/Medicare resource which provides the guidelines and documentation requirements?
Thank you so much.
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CPT 77336 is not billed for a treatment delivery course of SRT (CPT 77401). Here's an excerpt from the ASTRO Coding Resource:

1731530061134.png
 
If you're going to be auditing radiation oncology regularly, I'd highly recommend having a copy of the ASTRO book I mentioned above. It will provide a lot of context for you.

However, if you don't have access to that, you can also find the information in the CPT book. This excerpt is from the section for Radiation Treatment Delivery - the section that contains 77401.

1731531384327.png
:
 
sls314 said:
CPT 77336 is not billed for a treatment delivery course of SRT (CPT 77401). Here's an excerpt from the ASTRO Coding Resource:

View attachment 7562
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Thank you so much for the information and resources provided, it does help. I did want to clarify, though, that the dermatologist does not bill both codes on the same day. What I meant to say is that the dermatologist is doing ongoing SRT and then also billing for the 77336 once per 5 fractions. So my question is - can the provider performing the SRT also be doing the medical physics consultation & billing for it themselves, or is the medical physics typically done by someone else?
 
medicalauditor said:
Thank you so much for the information and resources provided, it does help. I did want to clarify, though, that the dermatologist does not bill both codes on the same day. What I meant to say is that the dermatologist is doing ongoing SRT and then also billing for the 77336 once per 5 fractions. So my question is - can the provider performing the SRT also be doing the medical physics consultation & billing for it themselves, or is the medical physics typically done by someone else?
Click to expand...

The instructions from the CPT book apply to the full course of treatment, not just the date of service. 77336 should not be reported for any date of service for SRT.

To answer your other question though, 77336 is for services rendered by a medical physicist. For radiation therapy where 77336 is eligible to be billed, the radiation oncologist doesn't report it.

Typically the facility employs the medical physicist and bills the 77336 for the services of the physics staff.
 
sls314 said:
The instructions from the CPT book apply to the full course of treatment, not just the date of service. 77336 should not be reported for any date of service for SRT.

To answer your other question though, 77336 is for services rendered by a medical physicist. For radiation therapy where 77336 is eligible to be billed, the radiation oncologist doesn't report it.

Typically the facility employs the medical physicist and bills the 77336 for the services of the physics staff.
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Got it. Thank you SO much :-)
 
medicalauditor said:
Got it. Thank you SO much :)
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You're welcome!

It may help to understand what the CPT 77336 represents in case you get pushback from the dermatologist. (Of course, the CPT guidelines and the ASTRO publications are clear, but that doesn't mean you won't get push back anyhow.)

In the Continuing Medical Physics consultation (CPT 77336), a Medical Physicist is providing oversight and quality assurance for the technical aspects of the patient's treatment. They validate the dose delivery, review charts and documentation of dosimetry plans, calculations, and other items such as elapsed days, and cumulative dose.

This link from the American Association of Physicists in Medicine helps describe the scope of the profession and also the qualifications for a Medical Physicist: https://w3.aapm.org/medical_physicist/index.php

Hope this helps!
 
You are awesome! Thank you so much. This helps. I just have one more request. Since I don't have access to ASTRO, would you be able to attach the document that you provided a snapshot of? You're right when you say it's not necessary there won't be push-back from the provider who has been billing like this forever, so having all possible resources will help. If you can't send the document to me, I understand.
 
Hello

sls314 - I talked to the providers, coders and administrators, and as expected, there is push-back based solely on the CPT instructions that 77336 cannot be billed WITH 77401, which is considered to mean that it cannot be billed on the SAME DAY, and the 77336 was not billed on the same day as 77401. They are also not accepting guidance provided by ASTRO stating it is a third party and they will not accept anything other than what is in the CPT code book, or from CMS. I looked and looked, but can't find anything from CMS which clarifies that WITH does not just mean on the same day, it means "during the treatment cycle". I explained the scope of 77336, that it is an ongoing consultation and not just for the DOS, so when CPT says WITH, they are not talking only about the DOS, etc., but unless I can show them in black-and-white that this is what it means, they will not accept it. Do you know of a CMS or AMA resource which clarifies this? Thank you in advance.​

​

 
Would this suffice from the February 2016 CPT Assistant?

"A number of CPT codes cannot be reported when superficial radiation therapy is provided, including MeV treatment delivery codes (77402, 77407, 77412); clinical treatment planning codes (77261-77263); treatment device development codes (77332-77334); isodose planning codes (77306, 77307, 77316,-77318); radiation treatment management codes (77427, 77431, 77432, 77435, 77469, 77470, 77499); continuing medical physics consultation code (77336); and special physics consultation code (77370). Evaluation and management (E/M) services may still be reported separately, when appropriate, in cases when only superficial
radiation therapy (77401) services are provided."

Although they may have the same argument.
 
Rachel provided good information from CPT Assistant, which is an official AMA companion to the CPT manual.

Here's a screenshot from my electronic version of CPT Assistant.

1740434557189.png
 
rachaelwilleford said:
Would this suffice from the February 2016 CPT Assistant?

"A number of CPT codes cannot be reported when superficial radiation therapy is provided, including MeV treatment delivery codes (77402, 77407, 77412); clinical treatment planning codes (77261-77263); treatment device development codes (77332-77334); isodose planning codes (77306, 77307, 77316,-77318); radiation treatment management codes (77427, 77431, 77432, 77435, 77469, 77470, 77499); continuing medical physics consultation code (77336); and special physics consultation code (77370). Evaluation and management (E/M) services may still be reported separately, when appropriate, in cases when only superficial
radiation therapy (77401) services are provided."

Although they may have the same argument.
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Thank you, this definitely helps, because it says WHEN superficial radiation therapy is provided instead of with. But, you're right, they could still have the same argument. I will try.. Thanks so much.
 
sls314 said:
Here's also a link to an MLN with additional info:

The reason why those physicians can report E/M codes is because they CANNOT bill the other services with superficial radiation. (Normally E/M cannot be billed during radiation therapy treatment - it's allowed during superficial radiation ONLY because all those listed services cannot be billed separately by them.)



View attachment 7797
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Thank you. This makes sense and I will try my best to explain this to them. The problem is the use of the word WITH which is construed to mean on the same DOS. When someone decides they're not going to listen to reason and be stuck on semantics because it suits them, then...I wish CPT would clearly say "during" like ASTRO does. Thank you again, this definitely helps to make a stronger case.
 
medicalauditor said:
Thank you. This makes sense and I will try my best to explain this to them. The problem is the use of the word WITH which is construed to mean on the same DOS. When someone decides they're not going to listen to reason and be stuck on semantics because it suits them, then...I wish CPT would clearly say "during" like ASTRO does. Thank you again, this definitely helps to make a stronger case.
Click to expand...

Unless they are employing and billing for a qualified medical physicist, they aren't even providing the service described by CPT 77336.

Would they listen to reason on that?

The description of CPT 77336 is Continuing medical physics consultation, including assessment of treatment parameters, quality assurance of dose delivery, and review of patient treatment documentation in support of the radiation oncologist, reported per week of therapy

They're not even providing that level of service anyhow. They're trying to parse language on what "WITH" means but are willing to play fast and loose with what "PHYSICS" means.
 
sls314 said:
Unless they are employing and billing for a qualified medical physicist, they aren't even providing the service described by CPT 77336.

Would they listen to reason on that?

The description of CPT 77336 is Continuing medical physics consultation, including assessment of treatment parameters, quality assurance of dose delivery, and review of patient treatment documentation in support of the radiation oncologist, reported per week of therapy

They're not even providing that level of service anyhow. They're trying to parse language on what "WITH" means but are willing to play fast and loose with what "PHYSICS" means.
Click to expand...
Apparently, they are contracted with a company called Skincure oncology who has a medical physicist, and it is this medical physicist that does the consultation. I have no idea if the medical physicist is even doing what he/she is supposed to be doing, or is just providing standard documentation to show that med physics was done. Would this be ok - for the physicist to be employed by another company which has a contract with the practice?
 
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