Neurosurgery Coding Alert

Check for bundle in fluoro guidance with epidurals.

The new set of bundling edits in CCI 21.2 list epidural codes 62310-62319 as Column 1 with 77003 (Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures [epidural or subarachnoid]) as the Column 2 code. The descriptors for the affected epidural procedures are as follows:

• 62310 – Injection(s), of diagnostic or therapeutic substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), not including neurolytic substances, including needle or catheter placement, includes contrast for localization when performed, epidural or subarachnoid; cervical or thoracic

• 62311 – … lumbar or sacral (caudal)

• 62318 – Injection(s), including indwelling catheter placement, continuous infusion or intermittent bolus, of diagnostic or therapeutic substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), not including neurolytic substances, includes contrast for localization when performed, epidural or subarachnoid; cervical or thoracic

• 62319 – … lumbar or sacral (caudal).

“Though just released with CCI 21.2, this new edit is retroactive back to Jan. 1, 2015,” says Marvel J. Hammer, RN, CPC, CCS-P, PCS, ACS-PM, CHCO, of MJH Consulting in Denver, Co. “This is in support of the 2015 Medicare Physician Fee Schedule that stated Medicare was going to revert back to the 2013 RVUs for these codes but that image guidance would be prohibited from being separately paid with these epidural codes.”

The Medicare stance is contradictory to CPT® directives. Because the first quarter CCI edits for 2015 did not include a bundling edit, some practices mistakenly billed 77003 with these epidural codes and were paid.

“They thought that because they were paid by Medicare, it was appropriate to continue to bill these separately,” Hammer explains. “Practices that have been paid by Medicare in 2015 for 77003 with the 62310-62319 should consult their healthcare attorney about refunding the inappropriate payment for 2015 dates of service that was previously processed. Medicare contractors will likely go back through their payment files and be reviewing any payment for 77003 with these codes for the same session and request a refund.”

You can potentially bypass the bundling edit between 77003 and codes 62310-62319 with a modifier, but Hammer says the provider would need to use the fluoroscopic guidance with a different procedure from the epidural.

“CPT® has gradually been bundling the image guidance into percutaneous spinal procedures over the past few years,” says Gregory Przybylski, MD, director of neurosurgery at the New Jersey Neuroscience Institute, JFK Medical Center, Edison. “Since most of these procedures typically require image guidance for confirmation of placement, the work is being considered integral to the procedure and therefore not separately reportable. While the CPT® descriptors of these codes do not include the image guidance, CMS appears to have pre-emptively bundled the image guidance into this series of codes as well.”