I'm looking at claims from a facility that routinely bills for a BPP without an NST (76819) and then bills separately for the NST (59025), with a 59 modifier. The services are taking place in two different areas of the hospital (radiology and the OB floor). In the majority of the cases there are normal ultrasound findings (8/8), yet the NST is still performed. In addition I have two different physician charges; one bills for the BPP only and another bills for the NST (both use the 26 Modifier). There is no TC attaached to the facility claims. My questions are: 1. Isn't this unbundling, and 2. Shouldn't there be a medical indication for performing both tests (i.e. if either initial test is normal or reassuring why is a second procedure being performed? 3. Shouldn't the facility claims have a TC attached?

thanks in advance for any insight you can give me on this!