# Sequencing Modifiers 80 & AS



## pkidd (Feb 3, 2012)

Greetings!

Our practice has just learned about a 'new" rule by CMS about appending both modifier 80 (81/82) and AS when a PA-C/RNFA, etc assist at surgery.  We are Noridian.  We have only appended modifier-AS when our PA-C assisted the surgeon, but have had no denials for this on our claims.   I guess the rule has been in place for several years, but just not enforced.

Our question now is -- In which order should the modifiers be written?
My inclination is 80-AS, but our home office is insisting that it should be AS-80 and I'm not so sure about that.

How are you all submitting the claims? If I can find a reference or CMS documentation, that would be great. 

I appreciate your "assist"ance!
Pat Kidd, CPC, CGSC
Albany Surgical Associates
Albany, OR
pkidd@samhealth.org


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## btadlock1 (Feb 3, 2012)

pkidd said:


> Greetings!
> 
> Our practice has just learned about a 'new" rule by CMS about appending both modifier 80 (81/82) and AS when a PA-C/RNFA, etc assist at surgery.  We are Noridian.  We have only appended modifier-AS when our PA-C assisted the surgeon, but have had no denials for this on our claims.   I guess the rule has been in place for several years, but just not enforced.
> 
> ...



Why do you need both? That seems redundant...


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## CLCameron (Feb 3, 2012)

*CMS Rules*

We are coming across a flood of the same denials. They were trickling in at the beginning of January and we got a verbal heads up from Noridian. In the past week the volume has definitely increased. 

Noridian issued a bulletin addressing this on 01/30/2012 - https://www.noridianmedicare.com/cgi-bin/coranto/viewnews.cgi?id=EFkZAyFplAyuTbLBtn&tmpl=part_b_viewnews&style=part_ab_viewnews.

One of my A/R Reps was told by a representative at Noridian to put the AS and then the 80, but I've yet to find any guidelines regarding the sequencing to back that up. I would definitely be interested to see what others have found.


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## btadlock1 (Feb 3, 2012)

CLCameron said:


> We are coming across a flood of the same denials. They were trickling in at the beginning of January and we got a verbal heads up from Noridian. In the past week the volume has definitely increased.
> 
> Noridian issued a bulletin addressing this on 01/30/2012 - https://www.noridianmedicare.com/cgi-bin/coranto/viewnews.cgi?id=EFkZAyFplAyuTbLBtn&tmpl=part_b_viewnews&style=part_ab_viewnews.
> 
> One of my A/R Reps was told by a representative at Noridian to put the AS and then the 80, but I've yet to find any guidelines regarding the sequencing to back that up. I would definitely be interested to see what others have found.



"Note: *In addition to modifier 80, 81, or 82, be sure to append modifier AS.* If the modifier AS is not included, the claim indicates that the physician has served as the surgical assistant. It was brought to our attention that claims were mistakenly being allowed with only the modifier AS for PAs. The claims processing system has been updated with the October 2011 Quarterly Release. The use of the double modifier was, and is, still required for PAs."

Just because of the way that's worded, I'd think that the 80 goes first, but I could be wrong. What a dumb rule...there's no reason to use both. Actually, there's no reason to use the AS at all, when you're billing under the PA's own numbers; that modifier is meant to be used, when you're billing as the MD, for a PA who's assisting @ surgery. Oh well...


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