Correct Coding Initiative 101:
Understand Medicares CCI to Ensure Compliance
Published on Fri Sep 01, 2000
Unbundling coding for two or more procedures that should not be billed together is a major compliance problem. But many neurologists 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, neurologists 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 neurology practices 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. The CCI is particularly important to neurologists because the billing for many of the procedures they perform is guided by its policies. The CCI edits break down into two categories: Mutually exclusive codes and comprehensive/component pairings.
Mutually Exclusive Codes
Mutually exclusive codes represent services that cannot reasonably be performed during the same session. For example, a neurologist cannot perform a nerve conduction study without F-wave (CPT code 95900, nerve conduction, amplitude and latency/velocity study, each nerve; motor, without F-wave study) and a nerve conduction study with F-wave (CPT code 95903, nerve conduction, amplitude and latency/velocity study, each nerve; motor, with F-wave study) at the same site during the same testing.
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 classified 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 95813 (electroencephalogram [EEG] extended monitoring; greater than one hour) includes 95812 (electroencephalogram [EEG] extended monitoring; up to one hour).
The code 95813 cannot be billed together with 95812, according to the CCI, because the first hour of the EEG (95812) is included in the more complete procedure of 95813. Therefore, the first code 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, 95860 (needle electromyography, one extremity with or without related paraspinal areas) is followed by 95861 (needle electromyography, two extremities with or without related paraspinal areas). If the neurologist performs an electromyogram (EMG) of two extremities, [...]
