Neurology & Pain Management Coding Alert

In the fall of 2000, version 6.3 of the national Correct Coding Initiative (CCI) bundled E/M services with hundreds of diagnostic procedure codes. As a result, physicians were required to append modifier -25 (Significant, separately identifiable evaluation and management service by the same physician on the same day of the procedure or other service) to any E/M code reported on the same day as a procedure code and to provide documentation to substantiate that the E/M service was significant and separately identifiable. Following complaints from physicians and physician advocates, CMS suspended the portion of the edits bundling E/M and diagnostic procedures (i.e., those with a "XXX" global period) in early 2002 but continued to recommend that modifier -25 be appended to all E/M services billed with such procedures.

With the release of CCI 7.3 last November, CMS made changes in the verbiage defining XXX global periods to once again officially bundle E/M services with diagnostic procedures. "By changing this little, very obscure definition, CMS made it so one needs to append modifier -25 to demonstrate that the E/M was significant and separately identifiable from the diagnostic procedure," says Barbara J. Cobuzzi, MBA, CPC, CPC-H, CHBME, president of Cash Flow Solutions Inc., a physician reimbursement consulting firm in Lakewood, N.J. and vice president of the Coding and Reimbursement Network. Note that although not all payers are yet recognizing the changes instituted by CCI 7.3, in all cases in which a significant, separately identifiable E/M service is provided including those cases in which the E/M leads to the decision to perform a procedure with zero, 10 (i.e., minor surgery) or XXX global days you should append modifier -25.