The latest version of the National Correct Coding Initiative (NCCI) targets 92502-92700 and requires otolaryngologists and ENT coders to focus on three bundles that reinforce coding conventions. Although NCCI 9.1 is large, with almost 3,000 additions and 2,000 deletions, the edits will probably not shock you, says Cathy Klein, LPN, CPC, director of regional network services for Cardinal Health Initiatives LLC in Muncie, Ind. Instead, the most recent round of edits, the first since carriers incorporated the new CPTcodes, clarifies E/M reporting and reinforces coding to the highest specificity. NCCI 9.1, effective April 1-June 30, bundles: E/M Bundle Is No New News At first glance, you may be dismayed to see this first edit, which includes 99211 (Office or other outpatient visit for the evaluation and management of an established patient typically, 5 minutes are spent performing or supervising these services) with 92504 (Binocular microscopy [separate diagnostic procedure]),92526 (Treatment of swallowing dysfunction and/or oral function for feeding) and 92541 (Spontaneous nystagmus test, including gaze and fixation nystagmus, with recording). But because NCCI already includes this edit in its basic language, there's no need for alarm, says Pamela J. Biffle, CPC, CCS-P, an independent consultant in the Dallas/Fort Worth area and approved PMCC instructor. NCCI 7.3 established that codes that contain a global period of XXX days, such as 92504, 92526 and 92541, include a minor E/M. Therefore, regardless of NCCI 9.1's edit, you would not report an E/M in addition to these codes unless the nurse performs a significant, separately identifiable service, Biffle says. "For instance, the nurse evaluates a problem, such as a sinus or allergy problem, that has not resolved." In this case, you would append modifier -25 (Significant, separately identifiable E/M service by the same physician on the same day of the procedure or other service) to the E/M. CMS merely reinforces that binocular microscopy, oral function therapy and the spontaneous nystagmus test include a minimal E/M service, and 99211 is as minimal an E/M as is clinically possible. In fact, the nurse code is so minor that ancillary personnel, rather than the physician, usually provide the service. Analysis Includes Evaluation,Treatment Although the 99211 bundle confirms earlier NCCI tenets, the evaluative and therapeutic services edits break new ground. After CPT released the new 2003 codes, CMS had to analyze them and see if they warranted any new edits. In fact, most of the close to 3,000 deletions come from eliminating bundles of deleted codes. For the cochlear implant codes, CMS realized that the new codes (92601-92604) overlapped with existing speech/hearing evaluation and therapy codes (92506-92507). Adiagnostic evaluation as described in 92601 (Diagnostic analysis of cochlear implant, patient under 7 years of age; with programming), 92602 ( subsequent reprogramming), 92603 (Diagnostic analysis of cochlear implant, age 7 years or older; with programming) and 92604 ( subsequent reprogramming) includes speech/language evaluation (92506, Evaluation of speech, language, voice, communication, auditory processing, and/or aural rehabilitation status) and treatment (92507, Treatment of speech, language, voice, communication, and/or auditory processing disorder [includes aural rehabilitation]; individual). The physician or technician would have to evaluate the patient's speech and language to program or reprogram the stimulator, Klein says. In addition, any adjustments he or she made would be considered the treatment. Consequently, you should not bill 92506-92507 in addition to 92601-92604, she says. NCCI does not allow a modifier to override these bundles. Specificity Contains Generality Another edit that does not permit a modifier for unbundling involves five new FEES and FEEST codes. CPT 2003 created 92612 (Flexible fiberoptic endoscopic evaluation of swallowing by cine or video recording), 92613 ( physician interpretation and report only), 92614 (Flexible fiberoptic endoscopic evaluation, laryngeal sensory testing by cine or video recording), 92615 ( physician interpretation and report only) and 92616 (Flexible fiberoptic endoscopic evaluation of swallowing and laryngeal sensory testing by cine or video recording) to describe specific laryngeal studies. These new, more specific codes overlap with a previous general laryngeal study code (92520, Laryngeal function studies). Because the FEES/FEEST codes include a general study, CMS considers 92520 a component of 92612-92616, Biffle says. Therefore, reporting 92520 in addition to 92612-92616 is a misuse of the procedural codes.