Radiology Coding Alert

If your freestanding radiation oncology center employs its own radiation physicist, you probably think you can report all of his or her special consultation services (77336- 77370) directly to Medicare. In some cases, however, you may have to squeeze reimbursement for these services directly from the hospital.

Most local medical review policies (LMRPs) advise radiation oncology providers that CPT 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) and CPT 77370 (Special medical radiation physics consultation) are "technical services only" codes.

"The physicist provides the service for these procedures, which only carry reimbursement for the technical service," says Jeff Fulkerson, BA, CPC, supervisor of radiology billing at the Emory Clinic in Atlanta.

These technical services codes "are payable by Medicare Part B only in settings in which the technical component is payable, i.e., in the freestanding radiation oncology center that employs its own radiation physicist," according to the LMRP from Palmetto GBA, South Carolina's Part B carrier.

"If your freestanding center employs the physicist meaning that the center actually pays his or her salary and the physicist performs the procedure at the freestanding center, you can report the whole code, either 77336 or 77370, directly to the patient's Part B carrier," says Deborah I. Churchill, RTT, president of Churchill Consulting Inc., a Killingworth, Conn., consulting firm that offers audits, seminars and electronic coding applications.

CMS dictates that to report a technical service, you must not only employ the physicist (as defined by the Internal Revenue Service's employer/employee relationship requirements), but you must also own or lease the space at fair market value and own or lease the equipment (if the consultation requires equipment) at fair market value.

Unfortunately, your physics consultation patients won't always be covered under Part B, and freestanding radiation oncology centers shouldn't report these procedures to Part A carriers. According to the Montana Blue Cross/Blue Shield LMRP, 77336 and 77370 "services provided to hospital inpatients or outpatients are reimbursed under Medicare Part A."

What most LMRPs don't address is that sticky situation when a hospital inpatient presents to your freestanding center for these services. Often, the patients plan to undergo services (such as brachytherapy implant procedures) that the physician can only perform in an inpatient setting, but require a physicist's consult at your facility.

Suppose a urologist and a radiation oncologist implant a prostate seed for brachytherapy (55859, Transperinealplacement of needles or catheters into prostate for interstitial radioelement application, with or without cystoscopy; and 77778, Interstitial radiation source application; complex) at the hospital. Your qualified medical physicist performs a consultation, but the patient is technically an inpatient, so you cannot bill that service to the patient's Part B carrier.

Your only option is to submit your claim for the technical component to the hospital and collect reimbursement directly from it, Churchill says.

If your freestanding center often provides procedures for inpatients who require special physics consultation services, such as the various brachytherapy procedures that must be performed in an inpatient setting, you should work with a healthcare attorney to set up an arrangement with the hospital. This way, the hospital will reimburse you for your physicist's work. The agreement should allow the qualified medical physicist full reimbursement based on the freestanding center's commercial rate, rather than the variouscarriers' reimbursement rates, Churchill says.

Always maintain the referring physician's written request for your physicist's medical radiation physics consultation (77370), and keep a copy in the patient'smedical record. In addition, you should not report 77370unless your physicist responds back to the requesting physician with a detailed written report that includes his or her findings.