Reader Questions: Incomplete Screen Won’t Affect Frequency Limits

Question: Recently, our facility physician attempted a screening colonoscopy for a high-risk Medicare patient but, due to patient discomfort, was unable to complete the procedure. How can we report this?

California Subscriber

Answer: In a facility setting, for Medicare and other payers that follow Medicare guidelines, you should report an incomplete colonoscopy using the appropriate colonoscopy code (in this case, G0105, Colorectal cancer screening; colonoscopy on individual at high risk) appended with modifier 73 (Discontinued outpatient procedure prior to anesthesia administration). If appropriate, you could instead append modifier 74 (Discontinued outpatient procedure after anesthesia administration) to the colonoscopy code.

Medicare rules state, "Payment for covered screening colonoscopies, including that for the associated ASC facility fee when applicable, shall be consistent with payment for diagnostic colonoscopies, whether the procedure is complete or incomplete," according to CMS transmittal AB-03-114.

You are correct that Medicare subjects screening colonoscopies to frequency limitations, but reporting an "incomplete" screening should not affect your ability to report -- and be paid for -- a subsequent complete examination.

Transmittal AB-03-114 instructs Medicare carriers, "It is not appropriate to count the incomplete colonoscopy toward the beneficiary’s frequency limit for a screening colonoscopy because that would preclude the beneficiary’s being able to obtain a covered completed colonoscopy." The transmittal concludes, "If coverage conditions are met, Medicare pays for both the uncompleted colonoscopy and the completed colonoscopy whether the colonoscopy is screening in nature or diagnostic."

Keep documentation on hand: Medicare "would expect the provider to maintain adequate information in the patient’s medical record in case it is needed by the contractor to document the incomplete procedure," according to AB-03-114.

Resource: You can view CMS Transmittal AB-03-114 at http://www.cms.hhs.gov/Transmittals/Downloads/AB03114.pdf.

-- Reader Questions reviewed by Sarah L. Goodman, MBA, CPC-H, CCP, president of SLG Inc. in Raleigh, N.C.