Remember to exercise caution when using a modifier to break an NCCI edit. Chances are your coding software seamlessly implements the quarterly National Correct Coding Initiative (NCCI) edits, but you may face a denial without knowing why — unless you know how NCCI Procedure-to-Procedure (PTP) edits work. Have you ever been stumped when trying to interpret the most recent NCCI update or wondered why the Centers for Medicare & Medicaid Services (CMS) produces this comprehensive listing? If so, this one’s for you. We put together this handy guide chock full of expert advice in an attempt to answer those questions and help you use this valuable tool to improve your CPT® coding accuracy.
Focus on Why NCCI PTP Edits Matter “PTP edits were developed to promote national correct coding methods, to control improper coding leading to inappropriate payments for Medicare claims, and to prevent unbundling of services,” said Arlene Dunphy, provider outreach and education consultant at the Medicare Administrative Contractor (MAC) National Government Services (NGS) in the webinar, “The National Correct Coding Initiative and Medically Unlikely Edits.” Or, as CMS explains it, the purpose “is to prevent improper payment when incorrect code combinations are reported” by assembling “code pairs that should not be reported together for a number of reasons” (www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/). NCCI’s coding policies are based on the CPT® manual, the HCPCS Level II manual, national and local Medicare policies, and coding guidelines that national societies developed. PTP edit pairs, which are updated quarterly, are just one type of NCCI edit. There are also medically unlikely edits (MUEs) and add-on codes. Understand What Edit Pairs Are CMS creates an edit pair when it regards a specific service as being a component part of a larger, more comprehensive service. In PTP edits, when your provider submits two bundled codes, the Column 1 code is eligible for payment, but Medicare will deny the Column 2 code unless both codes are clinically appropriate, according to Dunphy. Also, your provider must include supporting documentation in the medical record. NCCI does not include all possible code combinations, so providers are obligated to code correctly, even if edits do not exist, Dunphy said. Services that are denied based on PTP code pair edits may not be billed to Medicare beneficiaries, and you cannot utilize an advance beneficiary notice (ABN) to seek payment. Make Sure To Know Why MUEs Matter In addition to PTP edit pairs, “CMS has created Medically Unlikely Edits, or MUEs, to reduce coding errors and fraud,” explains Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting Inc. in Lansdale, Pennsylvania. “MUEs represent the maximum number of times one service can be performed on one patient and are usually determined by such biological factors as how many organs or limbs typically exist in the human anatomy, or whether the service is gender specific. They are CMS’ way of deciding how many units you can bill on one service line,” Falbo further elaborates. Identify Different Modifier Indicators CMS assigns Column 1 status to the comprehensive service and Column 2 status to a code they regard as being a component part of the Column 1 service. Each PTP edit pair is then assigned one of three modifier indicators. An indicator of 0 means that the pair cannot be unbundled with an NCCI-associated modifier and that only Column 1 procedures will be paid in claims featuring both services by the same provider for the same beneficiary on the same date of service (DOS). An indicator of 1 means that both services may be reported together if an NCCI-associated modifier is appended to the Column 2 code and both services are eligible for payment. An indicator of 9 means the pair has been deleted, and that you can ignore the indicator. Example: Code 67010 (Removal of vitreous, anterior approach … subtotal removal with mechanical vitrectomy) is a Column 2 code to 66984 (Extracapsular cataract removal with insertion of intraocular lens prosthesis … without endoscopic cyclophotocoagulation), which means they are bundled together. However, since the modifier indicator for this PTP edit pair is 1, you may break the edit with an NCCI-associated modifier under certain circumstances, such as performing 67010 on the left eye and 66984 on the right eye. Bottom line: When it comes to PTP edit pairs, the Column 1 code is payable, and the Column 2 code is a component code that is only payable if certain criteria are met, according to Dunphy.
Append NCCI-Associated Modifiers Appropriately “You should have an in-depth knowledge of the procedure as well as anatomy to know when an NCCI-associated modifier should be allowed,” says Mary Pat Johnson, CPC, CPMA, COMT, COE, senior consultant with Corcoran Consulting Group. “This is especially true when it comes to the proper use of modifier 59 [Distinct procedural service],” notes Falbo. Modifier 59 is probably the most utilized and well-known modifier when it comes to PTP edits. “However, it’s also a widely abused modifier that some may use just to bypass an edit, so make sure you only append this modifier if it best describes the circumstances,” Dunphy advises. You should never use modifier 59 as a default modifier. Why? With the 59 modifier, payers cannot determine why the provider is unbundling the two codes and how they are supported in the documentation. That’s why Medicare and other payers are now instructing practices to replace -59 with the X{EPSU} modifiers, which further clarify the reason for unbundling the edit pair. X{EPSU} modifiers: Modifiers XE (Separate encounter…), XS (Separate structure …), XP (Separate practitioner…), and XU (Unusual non-overlapping service …) are a subset of modifier 59 and may be used instead of -59. Whether you report an X{EPSU} modifier or modifier 59 on your claim will depend on payer preference; never submit both. Also, documentation is key when using modifiers. The medical record must support the reason the two procedures should be unbundled and billed separately — “being performed on separate sites, at separate encounters, by different practitioners, or due to special circumstances,” explains Barbara J. Cobuzzi, MBA, CPC, COC, CPCO, CPC-P, CPC-I, CENTC, CMCS, of CRN Healthcare Solutions in Tinton Falls, New Jersey. Red flag: If your payer prefers the X{EPSU} modifiers, do not use -59. Doing so tells the payer that you do not understand why you’re unbundling the CPT® codes, which increases the chances of these claims being audited.