Correct Coding Initiative 101:
Understanding Medicares CCI Is Powerful Compliance Tool
Published on Tue Feb 01, 2000
Unbundlingcoding for two or more procedures that should not be billed togetheris a major compliance problem. But many surgeons dont understand this concept, which can lead to claim denials. By reviewing the basic ideas behind bundling, such as mutually exclusive and component and comprehensive codes, general surgeons can avoid such problems.
By far the largest source of bundling combinations, or edits, is Medicares national Correct Coding Initiative (CCI), which has developed coding policies and more than 120,000 edits for reimbursement compliance to better control improper coding.
Although the CCI has been in place since Jan. 1, 1996, many general surgeons still do not understand its impact on how they bill procedures. This has serious compliance consequences because Medicare auditors may construe billing for procedures bundled into others as fraud.
Mutually Exclusive Codes
The CCI is particularly important to general surgeons because the billing for many of the procedures they perform is guided by its policies.
For example, the CCI edits include 47715 (excision of choledochal cyst) and 47716 (anastomosis, choledochal cyst, without excision) because they are considered mutually exclusive (i.e., these codes represent services that cannot reasonably be performed during the same operative session).
In other words, you cant excise a choledochal cyst and then bill the anastomosis of the same cyst without excision.
Component and Comprehensive Codes
Approximately 11,000, or just less than 10 percent, of the CCIs 120,000 edits are categorized as mutually exclusive. The other 90 percent may be categorized roughly as bundlescomprehensive codes that include component codes. Physicians may not bill the component codes if they also charge for the comprehensive procedure.
For example, code 36216 (selective catheter placement, arterial system; initial second order thoracic or brachiocephalic branch, within a vascular family) includes code 36215 (selective catheter placement, arterial system; each first order thoracic or brachiocephalic branch, within a vascular family).
The 36215 cannot be billed together with the 36216, according to the CCI, because the surgeon has to thread the catheter through the first order arteries to access the second order. Therefore, the catheterization of the first order arteries is included in the second.
CCI further subdivides the comprehensive/component code category according to various principles used to determine the edit. These eight principles include:
1. CPT Definition. Some CPT codes are part of a series in which the first code becomes a component for the codes following it that refer back to the common portion of the procedure listed in the preceding entry. For example, 47600 (cholecystectomy) is followed by 47605 (with cholangiography). If the surgeon performs an open cholecystectomy with cholangiography, only 47605 may be billed because the 47600 procedure is a component of 47605 and appropriately bundled into that procedure.
2. [...]
