Oncology & Hematology Coding Alert

Watch out: E/M bundles don't always place 96446 in column 1.

January means new CPT codes and, inevitably, new Correct Coding Initiative (CCI) physician edits from CMS for those codes. CCI version 17.0 is effective Jan. 1, 2011, for physicians. For this version, "19,822 new edit pairs have been added to the database while 9,778 have been terminated, for a net gain of 10,044 new edit pairs," according to Frank Cohen, MPA, MBB, of the Frank Cohen Group, in his Dec. 14, 2010, "NCCI Version 17.0 Change Analysis" announcement.

The main edits you want to be sure to watch for are those related to new code 96446 (Chemotherapy administration to the peritoneal cavity via indwelling port or catheter).

Note Where 96446 Falls (Col. 1/Col. 2) for NME Edits

The 96446 non-mutually exclusive (NME) edits are largely what you would expect based on other chemotherapy code edits -- bundles with E/M, anesthesia, venipuncture and other vascular procedures, for example. You want to be sure to watch which is the column 1 code and which is the column 2 code for these bundles.

For instance: CCI places E/M codes 99217-99239 in the column 1 position and 96446 in the column 2 position. On the other hand, CCI places 96446 in the col1 position and E/M codes 99201-99215 in the column 2 position, as shown below:

Remember that if you report both codes in an NME edit pair without a modifier, Medicare (and payers who adopt these edits) will deny the column 2 code and pay you only for the column 1 code. The edits in the table above all have a modifier indicator of 1, meaning that you may override the edits with a modifier when appropriate, such as in the case of distinct, separately identifiable encounters.

Below is a sampling of additional NME edits for 96446:

79200 Edit Reminds You to Check ME Edits, Too

CCI also created a mutually exclusive (ME) edit for 96446. "Mutually exclusive procedures cannot reasonably be performed at the same anatomic site or same patient encounter," according to Medicare's CCI manual, chapter I, section P.

The edit places 96446 in column 1 and in column 2 is 79200 (Radiopharmaceutical therapy by intracavitary administration). This edit also has a modifier indicator of 1, so you may override the edit with a modifier when clinically appropriate.

Resource: To download the latest edits or the CCI manual, go to www.cms.gov/NationalCorrectCodInitEd/. The link to download the "NCCI Policy Manual" is at the bottom of that page. To reach the physician edits, click on the "NCCI Edits -- Physicians" link at the top left of the page.