Wiki How to code a multi level RFN and TON

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I'm billing for a physician who is doing a RFN to C2, C3, and C4 and third occiptal nerve (TON). He's doing radiofrequency to all levels including the third occiptal nerve. He wants to code the TON using 64650 because it's not within a facet joint. Which obviously is a lot less money not to mention I have to use modifier 51 because we're performing multiple procedures on the same day. Does anyone have any suggestions or comments on how this should be billed?
 
Below is part of a response I received from the AMA CPT Network, they stated it would be inclusive.

Inquiry Question:
I believe the below procedure should be coded as such: 64626 (C2), 64640 (TON), 64627 (C3), 64627 (C4) 77003

Is it appropriate to report 64640 for destruction of third occipital nerve by radiofrequency ablation?

Radiofrequency neuolysis cervical medial branches(facets) RIGHT X 4 Levels C2,TON, C3, C4 Fluoroscopy for needle guidance

Above was part of my question Below is part of their response

"64626 Destruction by neurolytic agent, paravertebral facet joint nerve; cervical or thoracic, single level

64627 x2 Destruction by neurolytic agent, paravertebral facet joint nerve; cervical or thoracic, each additional level (List separately in addition to code for primary procedure)

77003 x1 Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural, subarachnoid, or sacroiliac joint), including neurolytic agent destruction

"It would not be appropriate to report code 64640 Destruction by neurolytic agent, paravertebral facet joint nerve; other peripheral nerve or branch. The third occipital nerve is the medial branch of C-3 and its location is similar anatomically with performing a paravertebral facet joint injection. However, the difference is that the location of the third occipital nerve may
vary, so the physician may need to burn over a wider area to ensure capturing the third occipital nerve in the procedure."
 
Please note at the time of the above Q and A, this was prior to 2012. For dates of services after Jan 1st 2012, a unit of service is per facet joint treated, so C2-3, C3-4, & TON would represent two level procedure with 64633 64634.

AMA CPT Assistant Sep 2012
While the intent of the new code series has remained the same, the reporting of these procedures has changed:
•The vertebral level is of less significance than the number of facet joints treated, so the unit of service is per facet joint to adequately reflect the work performed.
•For consistency with other procedures involving vertebra in the CPT code set, these codes are structured based on spinal region:
•Codes 64633 and 64634 specify the cervical or thoracic region.
•Codes 64635 and 64636 specify the lumbar or sacral region.
•Codes 64634 and 64636 are add-on codes for each additional facet joint in the same spinal region.

•Image guidance and localization are required for the performance of paravertebral facet joint nerve destruction by neurolytic agent as described by codes 64633-64636.
 
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