Medicare Compliance & Reimbursement

Contrary to common belief, providers can indeed report multiple radiation treatment sessions on the same day -- as long as they adhere to Medicare's guidelines.

According to the Centers for Medicare & Medicaid Services' Program Memorandum A-03-020, "Codes 77401 through 77416 may be reported more than once per date of service only when radiation treatment is provided during completely different sessions." Providers can report only one of these codes for each treatment session no matter how many areas are treated or no matter how much radiation is delivered.

Although CMS does not define "completely different sessions," most Medicare intermediaries agree that the physician must maintain a six-hour break between the radiation treatments. And, the patient's medical record must clearly document the medical necessity of separate session scheduling (also referred to as "BID" or "hyperfractioning").

"You have to look at the nature of the radiation services," says Deborah Churchill, president of Churchill Consulting Inc. in Killingworth, CT. To bill two radiation treatment codes, the separate sessions have to be services that the physician would normally perform on different days, she says.

Suppose the physician treats a patient in the morning with two separate areas, Churchill says. "This constitutes only one treatment delivery code because you would normally address both of these areas during one session."

In other words, if the physician administers two unique treatments to the patient on the same day, they must report two separate treatment encounters using the appropriate code(s).

For example, "If a patient had a head or neck cancer, such as T1 cancer of the larynx (161.0-161.9), you might administer a lower-than-normal dosage of radiation to the patient, but we do that twice a day," says Diane Corder, facility administrator at Gwinnett County Radiation Therapy Center in Lawrenceville, GA.

"The per-treatment dosage is lower, but the overall dosage is higher than normal," says Corder. "The caveat: The insurer requires that we allow a minimum of six hours between therapies so the normal cells can recuperate." If the physician meets those requirements, both codes can be reported on the same date.

Churchill agrees. "The standard 'BID'break, based on utilization guidelines, is approximately six hours," she says. This technique is generally applicable for the following conditions: