Compliance for splitting colonoscopy and endoscopy procedures

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I understand commercial insurance companies frown upon separating colonoscopy and endoscopy procedures when a patient is scheduled to have both performed. What is Medicare's stance on requesting these procedures be performed on separate dates of service? If our facility creates a policy that clearly states anyone ages 65 and over can not have a colonoscopy and endoscopy scheduled on the same day, would this be subject to discipline from Medicare from a compliance issue?
 

thomas7331

True Blue
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What is the purpose of the policy? If it is for a legitimate medical reason and this is an accepted standard of care, then it should not be a problem. If it is to bypass multiple procedure reductions in order to gain increased revenue at the expense of the patients and the payers, then it could indeed result in sanctions. The decision as to whether or not to perform the procedures at the same session should be based only on what is best for the patients. I do find such a policy a little suspicious since it seems like it would put patients at a greater risk to have to undergo anesthesia twice if both procedures are required. But this kind of decision is something a physician or trained clinician would need to address.
 
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Just to add to the previous reply,
I think it is safe to assume that a
blanket
policy that changes a practice's billing patterns for Medicare patients will quickly get a MAC's attention. In addition,
the 2017 CCI manual was updated to state that providers should not split visits to avoid edits:

“MUE and NCCI PTP [procedure-to-procedure] edits are based on services provided by the same physician to the same beneficiary on the same date of service. Physicians should not inconvenience beneficiaries nor increase risks to beneficiaries by performing services on different dates of service to avoid MUE or NCCI PTP edits.”
 
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