Medicare rules account for the fact that multiple plans developed on the same day may represent planning for radiation treatments that could be performed weeks apart, not just plans for a single dose of radiation therapy, says Cindy Parman, CPC, CPC-H, principal and co-founder of Coding Strategies, a coding consulting firm in Dallas, Ga.
"Date of service is often an issue where isodose plans are concerned because both the plan for the initial treatment and an off-cord or boost plan may be created at the initiation of treatment," Parman says. "The isodose plan does not become part of the patient's course of treatment until it is signed and accepted by the radiation oncologist."
Defer Acceptance
The plans should either plot dosages for several areas of interest or be intended for separate treatment episodes to determine whether a radiation oncologist can rightfully bill for multiple ones. While only one may be reported for a given course of therapy, additional ones may be reported when field changes are required during the therapy.
For example, two isodose plans executed on the same day may be reported separately if the first one was plotted to determine dosage for the initial treatment of radiation therapy and the second was for a boost to be performed three weeks later.
In this case, the radiation oncologist should sign and date the first isodose plan and assign 77305-77315 on the initial date of service. The second should be signed and dated three weeks later when the radiation oncologist uses it to deliver boost therapy.
Seeking separate payment for same-day isodose plans, however, should be reserved for plans that are intended for distinct radiation treatments, Parman says. Each one that is accepted by the radiation oncologist should represent the one that is optimal for the patient's course of therapy on the date the therapy is delivered, she adds. If two isodose plans are printed to determine the optimal dosage of a single dose of radiation, the radiation oncologist may bill only for the one that was used to determine the dosage, and the second should be marked as "not used."
A Conservative Approach
The other option is more conservative. Rather than carry out several isodose plans for numerous episodes of radiation, oncology practices should create the isodose plan just before treatment, says Jim Hugh, MHA, senior vice president with AMAC, a reimbursement and billing firm based in Atlanta. "You should bill for one plan per day," he says.
Using this approach, you should still report 77305-77315 on separate days, and sign and date the plans on the same day as radiation treatment. The only difference is that the plans were designed on the day of each treatment, rather than both on the day of initial treatment.
Note: There is no advantage to choosing one method over the other. Both options are equally compliant.
Determine the Proper Plan Level
Once you determine a method, you must choose the appropriate level: simple, intermediate or complex isodose plan.
Simple (77305) includes one or more of the following characteristics:
Intermediate (77310) includes one or more of the following characteristics:
Complex (77315) includes one or more of the following characteristics:
Parman warns that too many radiation oncologists overcode isodose plans, erroneously choosing 77315 when a lower level is more appropriate. With advances in technology, there is an assumption that all of these should be coded as 77315. Parman and Hugh agree that most plans are likely to be complex, but Parman warns against automatically assigning 77315.
Hugh says some practices routinely undercode as well. He cautions radiation oncology practices not to simply count the areas of interest or ports, but also to review other parameters of isodose planning, such as imaging equipment. For example, if sophisticated imaging such as CT scan or magnetic resonance is used, but only on a single area of interest with only a few blocks, this may be appropriately reported as 77315 rather than 77305.