Radiology Coding Alert

As radiation oncology coders continue to grapple with the complex, multistep coding required by intensity-modulated radiation therapy (IMRT) treatment, numerous questions trail after their efforts.

For example, a reader from South Dakota writes in with the comment that "in reading the November 2002 Radiology Coding Alert, we saw there was an article on IMRT coding with a comment from Jim Hugh, MHA, in which he stated that until 90 days after the end of treatment, all E/M codes are bundled. He reminded people to review the first paragraph in the Radiation Oncology section of the CPT book, which explicitly states this."

This reader goes on to note that they have reviewed the 2003 CPT book and see the statement to which Hugh refers. However, she reports that at a March 2002 training session with Dr. Carl Bogardus, president of the Cancer Care Network, an oncology practice management consulting firm in Midwest City, Okla., "We were told that there is no longer a global period and that follow-up visits can be billed."

Also, according to the subscriber, "Our 2002 Medicare provider disclosure report for South Dakota does not list a global period for 77427 (Radiation therapy management, five treatments). Should we be billing these follow-up visits immediately following radiation therapy or not?"

In response to this inquiry, Linda L. Lively, MHA, CCS-P, RCC, CHBME, founder and CEO of American Medical Accounting and Consulting in Marietta, Ga., reminds readers that "the introduction to the Radiation Oncology section of the CPT Codes states that radiation oncology services include follow-up care during course of treatment and for three months following its completion."

In addition, Lively says, Chapter 18 of the ASTRO/ACR User's Guide contains a listing of all items considered to be included in the weekly treatment management and which are therefore not separately payable. This list includes a specific reference to "follow-up examination and care for 90 days after last treatment (whatever code billed)."

CMS updates the global surgery status list each year; however, this generally refers to surgical services that include a 10- or 90-day follow-up period as part of the total surgical package. Coding questions may arise unless you understand that the absence of a nonsurgical code on this list does not necessarily imply that the requirements of the CPT definitions or the ASTRO/ACR guidelines should be abandoned. "We recommend that you follow the CPT guidelines unless specific rules to the contrary are negotiated with your commercial or managed-care payers," Lively says.

CMS has been asked to make specific comments on this issue for clarification. In the absence of any specific reference to support making such a change in your billing practices and since the ASTRO/ACR guidelines are most often quoted word-for-word in the LMRP Lively says, "Don't bill during the 90-day follow-up period unless you received specific permission in writing from your carrier, or unless there is separate and distinct medical necessity for the E/M service."