Ambulatory Coding & Payment Report
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News Brief: CMS Clarifies Multiple Surgical Procedure Billing Somewhat









The Centers for Medicare and Medicaid Services (CMS) (formerly HCFA) has released new guidance to clarify its position on correct billing of multiple surgical procedures under the outpatient prospective payment system (OPPS) when these procedures are performed in the same session. But many hospitals are still finding it difficult to bill because of a glitch in some fiscal intermediaries' (FIs) software that rejects a line item.  

The guideline, issued in PM A-01-50 on April 12, went into effect July 1. It states:
 
"It is acceptable to bill a single charge under the revenue code that describes where the procedure was performed (e.g., operating room, treatment room, etc.) on the same line as one of the surgical procedure CPT/HCPCS codes and bill the other procedures using the appropriate CPT/HCPCS code and the same revenue code, but with '0' charges in the charge field." The CMS also offers an example of how the guideline should be implemented, as shown in the table.
 
According to CMS, the charge for both surgical procedures in this example is reflected in the $300 charge shown on the line with procedure code 12011. However, some hospitals that follow this example and insert a "0" in the charge field for the second procedure code (12035 in this example) are rejected, according to Shirley Angleton, CHFP, a consultant with Boyce and Associates Healthcare Consulting of Golden Meadow, La. 

"Some fiscal intermediaries are rejecting the $0 line items and telling hospitals they must have at least $1 in that line item for surgery after the first true charge in the first line item." If you were to follow these rules in the previous example, the charge for code 12035 would be entered as $1, not "0." 
 
Apart from this glitch, Angleton says the guideline helps reduce the confusion. "Because APCs are new, the majority of hospitals never charged for procedures, only for the E/M visit," she says. "That's how they got around the confusion and the difficulty."  
 
Angleton says the guidance in the program memorandum is "right on." And, she adds, the problem with billing for multiple surgical procedures in the same session extends not just to the ED but also to the operating room (revenue center code 360). Angleton's advice: If you're having claims rejected based on entering a "0" in the charge field, consult your FI on how to deal with it.

- Published on 2001-07-01
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