Cardiology Coding Alert

If you're wondering about pay for right atrium and right ventricular lead repositioning (33215) in the aftermath of the NCCI 9.3 edits, there's some good news: Recent updates to the version 9.3 edits for 33215 signal additional reimbursement opportunities for some practices.  But potential reimbursement cuts loom on the horizon for many implant-related CPT codes.    
 
NCCI edits now bundle the new right atrial/ventricular lead repositioning code (33215, Repositioning of previously implanted transvenous pacemaker or pacing cardioverter-defibrillator [right atrial or right ventricular] electrode) into most of the pacemaker/defibrillator codes with the exception of 33212 for inserting or replacing single-chamber pacemaker generators, 33213 for dual-chamber pacemaker generator placement, and 33226 for LV lead repositioning. (See "Get the Lowdown on New Coronary Intervention, Pacer Bundles" in the November 2003 Cardiology Coding Alert for more on these and other NCCI 9.3 edits.)
 
All of these edits except 33224 and 33225 have an indicator of "0," meaning you can't override the edit with an NCCI-approved modifier. Codes 33224 and 33225 have an indicator of "1," which means you can append an NCCI modifier for payment. These edits went into effect on Oct. 1, 2003, except the 33225 edit, which was effective on Jan. 1, 2003.

33215 Switches Columns

Prior to version 9.3, NCCI released edits involving these code combinations. These edits, however, listed 33215 (the repositioning code) as the column 1/comprehensive code and listed the implant codes (such as 33208) as the column 2/component codes, says Ellen Griffith, CMS spokeswoman.
 
Griffith confirms that CMS did not intend to list 33215 as a column 1 code. The impact of this column 1/column 2 mix-up is that claims with these codes reported together would have been paid at a less-than-appropriate amount, Griffith says. Specifically, because NCCI bundled the higher-priced implant service (such as 33208) into the lesser-priced repositioning service (33215), carriers would have paid claims at the rate for the lesser-priced service instead of the higher-priced service, she says.

Get Reimbursed for Underpayment

If you didn't get the reimbursement you deserved for 33215 because of the column error, you may be able to recoup your losses.
 
"Providers who have been paid for 33215 [the procedure with the lower work RVU] instead of the current column 1 procedure with the higher work RVU may request an appeal to recoup the additional payment, but only after the implementation of the NCCI version 10.0 on Jan. 5, 2004, or after," Griffith says. "The allowance of an appeal for this type of edit change has been our procedure in the past." 
 
This would represent a substantial increase in reimbursement for those denials - possibly up to a 300 percent increase in reimbursement for claims in which  device implants were bundled into the lead repositioning service, coding experts say.
  
Watch NCCI 10.0 for Changes

NCCI version 10.0 of NCCI (effective Jan. 1, 2004) should list the effective dates for these edits as July 1, 2003, Griffith says. The current effective date of Oct. 1, 2003, leaves a gap from July 1 to Sept. 30 when no edits related to these code combinations were in effect. "It was never CMS' intent to delete these code pair edits; it was CMS' intent to reverse the order of the codes," she says.               

RVUs for Pacer/Defib Codes Under Scrutiny

CMS may be reassessing the relative value units (RVU) for many of the pacemaker/defibrillator codes, according to a June 18, 2003, letter CMS sent to the American College of Cardiology (ACC).
 
CMS indicated that it would "consider reviewing these edits once its concerns about the work valuation of these codes is addressed." CMS' concern is that the relative value units for many of the services in the pacemaker/ defibrillator section of CPT were set with the understanding that they included the work of lead repositioning during the 14-day postimplant period. Now that this 14-day wait period has been reduced to just one day, CMS "wonders whether the affected codes need to go to RUC for revaluation." Therefore, we may see an RVU reduction for many of these services in the future because of the change in the lead repositioning postimplant period.