General Surgery Coding Alert

Latest CCI Bundles E/M to Codes With No Global Period

Effective Oct. 30, 2000, evaluation and management (E/M) services performed at the same time as procedures that do not have a global period are considered bundled to those procedures unless they are significant and separately identifiable and have modifier -25 (significant, separately identifiable evaluation and management service by the same physician on the same day as the procedure or other service) attached.

The new policy, which was proposed by the Health Care Financing Administration (HCFA) in the Nov. 2, 1999, Federal Register, has been implemented in version 6.3 of the national Correct Coding Initiative (CCI). More than 57,000 codes are affected by the policy shift.

Until now, HCFAs global surgery payment policies (which can be found in section 4820 of the Medicare Carriers Manual) have applied only to procedures with global periods of zero, 10 or 90 days, as shown on the national Physician Fee Schedule Database.

When the new policy was proposed, HCFA said it was designed to prevent the practice of physicians reporting an E/M service code for the inherent evaluative component of the procedure itself. According to HCFA, The basis for this policy is that because every procedure has an inherent E/M component, for an E/M service to be paid separately, a significant, separately identifiable service would need to be documented in the medical record.

The category of codes most affected by the new policy is radiology, where more than 27,000 edits with E/M codes have been published. There are 2,776 edits in the respiratory system/surgery section (30000-39999) of the CPT manual. The pathology/lab section (80000-89999) has 4,268 edits. The 90000 series (which includes E/M as well as medicine and diagnostic services ) has 17,354 edits, and supplemental (HCPCS) codes have 3,507 edits.

The remaining sections of the CPT manual included fewer edits. In the integumentary section (10000 series), only 726 edits have been made. The digestive system/surgery section (40000 series) includes 462 edits. The 50000 series (male and female reproductive and urinary systems) contains 162 edits; and the 60000 series has 132 edits. The musculoskeletal system (20000 series) contains no new edits.

How to Optimize General Surgery Coding

Although general surgery is less affected than other specialties by the changes, surgeons are likely to encounter situations when modifier -25 will need to be appended to an E/M procedure.

For example, if the surgeon performs significant, separately identifiable E/M (such as E/M that led to the service) on a new patient and then introduces a needle or intracatheter into one of the patients peripheral veins for diagnostic purposes (36000), the appropriate-level E/M code (9920x) would be billed with modifier -25 attached, in addition to the 36000.

If, however, the surgeon only performs a preprocedure evaluation of the [...]
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