Latest CCI Bundles E/M to Many Procedure Codes
Published on Wed Nov 01, 2000
Effective Oct. 30, 2000, evaluation and management (E/M) services are considered bundled to a multitude of procedures unless they are significant and separately identifiable and have modifier -25 (significant, separately identifiable evaluation and management service by the same physician on the same day as another procedure or service) attached.
The new policy, which was proposed by the Health Care Financing Administration (HCFA) in the Nov. 2, 1999, Federal Register, has been implemented in version 6.3 of the national Correct Coding Initiative (CCI). More than 57,000 codes are affected by the policy shift.
When the new policy was proposed, HCFA said it was designed to prevent the practice of physicians reporting an E/M service code for the inherent evaluative component of the procedure itself. According to HCFA, the basis for this policy is that, because every procedure has an inherent E/M component, for an E/M service to be paid separately, a significant, separately identifiable service would need to be documented in the medical record.
The following codes, used often in neurology practices, are a just a few examples of services affected by this edit:
95970 electronic analysis of implanted neuro-
stimulator pulse generator system (e.g., rate, pulse
amplitude and duration, configuration of wave form,
battery status, electrode selectability, output
modulation, cycling, impedance and patient compliance measurements); simple or complex brain, spinal cord, or peripheral (i.e., cranial nerve, peripheral nerve, autonomic nerve, neuromuscular) neurostimulator pulse generator/transmitter, without reprogramming;
95971 simple brain, spinal cord, or peripheral
(i.e., peripheral nerve, autonomic nerve, neuromuscular) neurostimulator pulse generator/transmitter, with intraoperative or subsequent programming);
95972 complex brain, spinal cord, or peripheral
(except cranial nerve) neurostimulator pulse
generator/transmitter, with intraoperative or
subsequent programming, first hour; and
95974 complex cranial nerve neurostimulator pulse generator/transmitter, with intraoperative or subsequent programming, with or without nerve interface testing, first hour.
Tiffany Z. Eggers, JD, MPA, policy director and legislative counsel for the American Association of Electrodiagnostic Medicine, adds that modifier -25 must be appended even if the E/M and the procedure are performed at different locations. She also cautions that physicians who do not use the modifier may be accused of performing medically unnecessary procedures or fraudulent billing.
Currently, a coalition led by the American Academy of Neurology and representing the American Academy of Sleep Medicine, American Academy of Physical Medicine and Rehabilitation, American Association of Electrodiagnostic Medicine, American Clinical Neurophysiology Society, American Society of Electroneurodiagnostic Technologists, American Society of Neurophysiological Monitoring, and the National Association of Epilepsy Centers, is continuing to meet with HCFA in hopes of gaining a reversal of this policy. As of Oct. 30 despite the added time and effort that will be required for practices to gain a full understanding of what procedure codes [...]
