Oncology & Hematology Coding Alert

Reclaim Your Denied IMRT and Dosimetry Payments With NCCI, Version 9.2

If Medicare denied your separate billing of 77300 and 77301 when your oncologist performed an intensity modulated radiotherapy (IMRT) plan and simple dosimetry on the same day, you now have a chance to collect some back pay.

The National Correct Coding Initiative (NCCI), version 9.2, effective July 1, unbundles 77301 (Intensity modulated radiotherapy plan, including dose-volume histograms for target and critical structure partial tolerance specifications) and 77300 (Basic radiation dosimetry calculation, central axis depth dose calculation, TDF, NSD, gap calculation, off-axis factor, tissue inhomogeneity factors, calculation of nonionizing radiation surface and depth dose, as required during course of treatment, only when prescribed by the treating physician) for radiation oncology practices and freestanding clinics. Therefore, you may resubmit any claims CMS denied based on this edit between April 1, 2002, and June 30, 2003.

For example, prior to July 2003, your radiation oncologist treated a patient for nasopharyngeal cancer (147.9) with an IMRT (77301) to protect the parotid, as well as other salivary glands and the optic nerves. Your physician used computer software to verify the IMRT computer's report of five dosimetry calculations (77300), but CMS paid you only for 77301, not 77300.

Now, because of the dosimetry and IMRT unbundling, you should submit 77300 to charge for the work your oncologist performed in verifying the five calculations. But CMS will not "automatically" reimburse you, says Cindy C. Parman, CPC, CPC-H, RCC, principal and co-founder of Coding Strategies in Atlanta.

"In the past, CMS would reverse a bundling edit or a policy and instruct the carriers/fiscal intermediaries to 'automatically' reprocess the denied charges for payment," Parman says. You must resubmit any denied claims if you want Medicare to pay you.

Verify IMRT Calculations

CMS instructs carriers to reprocess the charges only when the coder or biller resubmits the claim, Parman says. Every office has a different billing system, but Parman offers general advice for resubmitting past dosimetry calculations:

You should determine how many 77301 services you billed that may have included bundled calculations, she says. Suppose your radiation oncologist administered IMRT treatments for five patients with neck cancer (195.0) in the last year. You could review the number of dosimetry calculations for each treatment and bill accordingly, she says.

But here's a cautionary note: To justify your charge for 77300, your radiation oncologist must have separately verified the IMRT computer's dosimetry calculations on the same day as the 77301 services, says James E. Hugh III, MHA, vice president of AMAC, a consulting, coding and billing firm in Atlanta. If your physician didn't verify the calculations, then the IMRT computer "did all of the work," he adds.
 
Also, you should avoid returning to the original report several months later to verify the calculations so that you can receive payment, Hugh says. CMS' edit reversal affects only those 77300 dose calculations that your oncologist performed on the same date of service as 77301.

Get Filing Procedures in Writing

Now that NCCI has deleted the bundling edit, don't assume that you will travel an easy road to payment for 77300. Instead, you must adhere to specific filing procedures when you resubmit the code to ensure payment for your physician's work. In other words, you don't want to spend time refiling a claim only to have Medicare reject it due to improper submission. Hugh offers the following tips:

  •  Before you submit 77300, check with your local Medicare carrier or private insurer for details regarding the company's particular filing process no carrier follows one system, Hugh says. Also, make sure your insurer explains the filing procedures to you in writing, not over the telephone. Later, if your carrier denies your claim based on improper submission, you'll have proof that you followed the carrier's instructions.

  •  Most non-Medicare insurers will require hardcopy claims of 77300, which you should have on file from the previous submission of 77301, Hugh says. In addition, write a letter to a specific person in the claims department that explains why you're resending a charge for 77300. For example, tell the insurer that NCCI, version 9.2, deleted the bundling of 77300 with 77301 when your oncologist performs the services on the same day. Note that the deletion is retroactive to April 1, 2002. Also include a copy of the NCCI edits with your letter.

  •  Never send a hardcopy claim for 77300 that includes other codes your carrier has already paid. For instance, your oncologist administered an IMRT treatment plan for pelvic cancer (195.3), which required four calculations, all of which your physician verified. Also, your physician performed his or her consultation services. You billed and your carrier reimbursed you for 77301 and 77336 (Continuing medical physics consultation, including assessment of treatment parameters, quality assurance of dose delivery, and review of patient treatment documentation in support of the radiation oncologist, reported per week of therapy). But when you file a claim for 77300, you cannot include 77301 and 77336 because CMS has already paid you for the work.
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