# Complex closure



## JYSPA (Feb 2, 2016)

Physician bills 21012,13131-59. They bundle per CCI. Is it allowed to unbundle for same lesion/location?


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## mitchellde (Feb 2, 2016)

No you do not bill separately for the closure when billing the 21012.  The 21012 includes the closure as a part of the procedure.


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## CodingKing (Feb 3, 2016)

I can see where the thought process is going with this question. Most surgeries include closure no matter the type. It's mainly in the integumentary section where certain procedures only include simple or intermediate because complex is not as common. Most other procedures it's expected that the closure type will be intermediate or complex so it's already included when they figured the value of the procedure


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## JYSPA (Feb 3, 2016)

I use Encoder Pro and it states in instruction page for 21012 - "Excludes Complex repair ". 

And according to our dermatology coder, commercial payors have not been denying.

And to add to that confusion, there is CPT assistant April, 2010 that states :

"New Musculoskeletal
 System Guidelines

Whether reporting the excision or radical resection of soft tissue tumors from the subcutaneous, fascial or subfascial layer, appreciable vessel exploration and/or neuroplasty should be reported separately. Simple and intermediate repair closures are included in the excision procedures, but if complex repairs with extensive undermining or other techniques are performed to close a defect created by a lesion excision, the complex repair codes are reported -separately. The excision of musculoskeletal lesions (tumors), includes the dissection or elevation of tissue planes in order to allow resection of the tumor, and therefore, those services are not reported separately. The code selection for musculoskeletal lesion excisions is determined by measuring the greatest diameter of the tumor, in addition to the narrowest margin required for the complete excision of the tumor, based on the physician’s judgment, at the time of the excision. The radical resection of soft tissue tumors may be confined to a specific layer, for instance the subcutaneous or subfascial tissue, or it may involve the removal of tissue from one or more layers. Radical resection of soft tissue tumors is most commonly used for malignant or very aggressive benign tumors."

I don't agree to bill 21012 with any kind of closure if it bundles but there are 2 other coders here who thinks can be billed together with supporting (above) sources ..


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## CodingKing (Feb 3, 2016)

I didn't know about this today but there is a whole manual to go along with CCI edits.  Its called National Correct Coding Initiative Policy Manual for Medicare Services. I downloaded it from the CMS website I'm enjoying reading it and learning a lot.

https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/Downloads/2016-NCCI-Policy-Manual.zip


According to chapter 4 (20000 Series) Section H.28. 



> Closure/repair of a surgical incision is included in the global surgical package. Wound repair CPT codes 12001-13153 should not be reported separately to describe closure of surgical incisions for procedures with global surgery indicators of 000, 010, 090, or MMM.



I found a few other chapters with the exact quote. Only the integumentary section included language about intermediate and complex not being bundled. The only ones they mentioned are the ones the CPT book says its not included. 

In reading the introductory pages, i learned even if there is not a CCI edit list is not all inclusive its only the most common or most abused code combinations. You can always appeal this but there is a strong chance it would be turned down for any payers that use NCCI.


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