Cardiology Coding Alert

What you should report when you don't own the equipment

Do pacemaker representatives come to your practice to perform checks on pacing equipment you do not own? If so, you'll need to know how to bill for your device interrogation/reprogramming services accurately. Not knowing how to bill these services - especially the technical component - could attract unwanted payer scrutiny.

Append Modifier -26 for Rep Checks

 When your practice doesn't own the equipment, and the device representative conducts the interrogation, you should report an analysis code, such as 93732 (Electronic analysis of dual-chamber pacemaker system [includes evaluation of programmable parameters at rest and during activity where applicable, using electrocardiographic recording and interpretation of recordings at rest and during exercise, analysis of event markers and device response]; with reprogramming), and append modifier -26 (Professional component), cardiology coding experts say.
 
If the physician doesn't own the equipment or pay the personnel, he or she should bill only the professional component, says Douglas L. Wood, MD, former chairman of the American College of Cardiology's (ACC) Coding and Nomenclature Committee.
 
Likewise, the North American Society of Pacing and Electrophysiology (NASPE) states in the latest edition of its coding guide that the "individual performing the evaluation must be employed by the MD in order to bill globally for the professional and technical services when testing and/or reprogramming is performed in the physician's office."
  
Many cardiology practices are careful about following these guidelines. "We do not bill if a rep who is not our employee does the check," says Rebecca Sanzone, CPC, billing manager for Midatlantic Cardiovascular Associates of Baltimore.

Solve the Programmer Ownership Quandary

So, what should you do when a practice-employed technician, such as a non-physician staff member, performs the interrogations with equipment not owned by the practice? You think billing the technical portion of the interrogation service is inappropriate if your practice does not incur the equipment expense.
 
To better determine whether to bill the technical portion, take a look at the following breakdown of the relative value units (RVUs) for 93732, a frequently reported device interrogation code. Keep in mind that practice expense RVUs include three components: (1) nonphysician clinical staff expenses, (2) medical supply costs, and (3) the medical equipment costs associated with the service. Total RVUs (0.54) multiplied by the current conversion factor of $36.7856 yields an unadjusted national allowed amount of $19.86 for 93732.
 
The practice expenses for 93732 include 18.8 minutes or $13.23 of nonphysician staff time, $3.16 in medical supply costs, and $2.37 in medical equipment expenses.
 
Indeed, the practice expenses for programmers - the devices used to interrogate/reprogram pacemakers and internal cardioverter defibrillators (ICDs) - are minimal, says Brian Outland, CPC, NASPE's manager of regulatory and reimbursement affairs. Most of the $2.37 medical equipment expense ($2.24) is for the software and the programmer. In effect, the medical equipment expense for 93732 ($2.24) is only 3 percent of the code's global fee. Therefore, ownership of the programmer may not be as critical as previously thought.
 
In fact, the largest part of the practice expense is associated with the nonphysician staff member's services. Therefore, if a practice employee such as a nurse - not a device rep or hospital personnel - performs the interrogation, you should charge the technical component and claim reimbursement for the practice expense incurred, Outland says.
 
Note: CMS is developing definitive advice on interrogation billing, so watch for this information in future issues of Cardiology Coding Alert. For more information on calculating RVUs for 93732 and other codes, go to http://www.cms.gov/physicians/pfs/default.asp.