If your claims fell victim to these erroneous bundles, now's the time to resubmit. Staying up to date on Provenge coding rules certainly keeps you on your toes. First, Medicare said you couldn't report an administration code with Provenge code Q2043 (Sipuleucel-t, minimum of 50 million autologous cd54+ cells activated with pap-gm-csf, including leukapheresis and all other preparatory procedures, per infusion). Then, even after CMS changed that rule, a Correct Coding Initiative (CCI) edit bundled certain administration codes into Q2043. Good news: Take Advantage of Retroactive Deletion CCI version 18.1, effective April 1, 2012, deletes edits bundling the following codes into Q2043: Key: Action point: In fact, several Medicare Administrative Contractors (MACs) have posted the following information: "CMS has instructed Medicare contractors to adjust claims for dates of service on and after Fri July 1 containing CPT® code 96365 that were denied and not paid due to the bundle editing, when brought to their attention. Providers may, beginning Sun Apr 1, request contractors to adjust claims for administration of PROVENGE® that were denied for this reason." (As an example, see the announcement posted by J5 Part B MAC WPS Medicare at http://wpsmedicare.com/j5macpartb/publications/news/cms_news/2012-0319-info-provenge.shtml.) Be sure you catch that you must be the one to initiate reprocessing. There won't be an automatic adjustment, says Lisa S. Martin, CPC, CIMC, CPC-I, chargemaster specialist for OSF Healthcare System in Peoria, Ill. Review Current Transmittal's Admin Coding Rule The edit deletions raise two issues that are key to clean Provenge claims. The first issue is that Medicare policy does allow reporting a code for administration in addition to Q2043. Consider this timeline of Provenge-related transmittals and what they reveal about reporting admin codes: "Please note the administration of PROVENGE® can be billed separately." Prevent a $66 Mistake With This Strategy The second issue raised by the edit deletions is whether they indicate that Medicare expects you to use 96365 as the admin code for Provenge. The reality is you need to verify whether your payer wants you to use 96365 or 96413 (Chemotherapy administration, intravenous infusion technique; up to 1 hour, single or initial substance/drug). Why 96413? Smart move: For example, Wellmark Blue Cross and Blue Shield and Noridian Medicare both instruct their providers to report 96365, as these policies show: In contrast, J12 MAC Novitas indicates it expects to see 96413 reported for administration (www.novitas-solutions.com/bulletins/all/news-02172011.html). Fee impact: Resources:
In Transmittal 2254 CMS announced that Q2043 included all related services. The transmittal specifically listed administration as not separately billable. So at that point, the now-deleted edits made sense.
CMS rescinded Transmittal 2239 and replaced it with Transmittal 2380, also effective June 30, 2011. This current transmittal again makes it clear that payers should reimburse for administration in addition to Q2043 (www.cms.gov/transmittals/downloads/R2380CP.pdf).