Neurology & Pain Management Coding Alert

Answer: The HCPCS modifier -GA (waiver of liability statement on file) should be appended only under the following circumstances: Prior to performing a procedure that Medicare is likely to deny, the neurologist notifies the patient in writing of his or her belief (and the reasons for that belief) that the service would be denied by Medicare, says Patricia Niccoli, HBMA, a coding and compliance expert from ElectroAge Billing, a physician billing service in Phoenix.

The patient must, in writing, state that he or she understands the neurologists statement and the patient must agree, in writing, to pay for the service. This written document is a waiver and it must cite the specific service for which Medicare is likely to deny payment.

Marlene Smith, billing manager for Complete Wellness in Nashville, Tenn., a billing company responsible for overseeing the coding, compliance, and collections for individual and multispecialty clinics nationwide, cautions that individual Medicare providers in particular states may have their own requirements for the use of HCPCS modifiers and it is in the neurologists best interests to request a copy of any such requirements from the local carrier so that the rules may be reviewed and followed. Variations in policy also may exist for multidisciplinary facilities as opposed to neurology-only providers.

Smith adds that with the -GA modifier, the patient must sign the waiver for non-covered services for each visit. A single, blanket agreement or release will not satisfy the requirements of most Medicare carriers. She urges neurologists to bill all services even if the neurologist strongly believes he or she will not be paid.

Smith says that the -GX modifier is used in many states to describe non-covered services when a Medicare denial is required to bill secondary insurance.