Wiki Billing & documentation for CPT code 77336 - Continuing medical physics consultation

[medicalauditor]

I am auditing a dermatologist, and I have this scenario: The dermatologist (Dr. A) is billing CPT code 77401 for performing SRT, and Dr. A also bills CPT code 77336 for medical physics consultation. Both chart notes are signed off by Dr. A. I am assuming that the SRT was actually done by a radiation therapist but is billed under Dr. A as incident-to, however there is no documentation of who the radiation therapist is, or of the service being incident-to - the chart looks like Dr. A did the SRT and is signed off by Dr. A. Also, the chart note for the medical physics consultation states that the consultation is being provided "per the request of Dr. A" implying that someone other than Dr. A is actually doing the medical physics consult, but the note is signed off by Dr. A and also billed by Dr. A. There is no mention of the physicist who did the consult. I am not too familiar with oncology so would appreciate some help here. My first question is:
1. Considering that the 77336 code description states that the service is "in support of the radiation oncologist", can this be billed by the same provider who is doing the SRT? Even if the people doing the SRT and the med physics are 2 different people, can the 2 services be billed by the same provider?
2. Secondly, how should the 2 services be documented and who should be signing off on them?
3. Does 77336 even apply to SRTs?
4. Can you please provide a link to the CMS/Medicare resource which provides the guidelines and documentation requirements?
Thank you so much.

 

[sls314]

I am auditing a dermatologist, and I have this scenario: The dermatologist (Dr. A) is billing CPT code 77401 for performing SRT, and Dr. A also bills CPT code 77336 for medical physics consultation. Both chart notes are signed off by Dr. A. I am assuming that the SRT was actually done by a radiation therapist but is billed under Dr. A as incident-to, however there is no documentation of who the radiation therapist is, or of the service being incident-to - the chart looks like Dr. A did the SRT and is signed off by Dr. A. Also, the chart note for the medical physics consultation states that the consultation is being provided "per the request of Dr. A" implying that someone other than Dr. A is actually doing the medical physics consult, but the note is signed off by Dr. A and also billed by Dr. A. There is no mention of the physicist who did the consult. I am not too familiar with oncology so would appreciate some help here. My first question is:
1. Considering that the 77336 code description states that the service is "in support of the radiation oncologist", can this be billed by the same provider who is doing the SRT? Even if the people doing the SRT and the med physics are 2 different people, can the 2 services be billed by the same provider?
2. Secondly, how should the 2 services be documented and who should be signing off on them?
3. Does 77336 even apply to SRTs?
4. Can you please provide a link to the CMS/Medicare resource which provides the guidelines and documentation requirements?
Thank you so much.

CPT 77336 is not billed for a treatment delivery course of SRT (CPT 77401). Here's an excerpt from the ASTRO Coding Resource:

 

[sls314]

If you're going to be auditing radiation oncology regularly, I'd highly recommend having a copy of the ASTRO book I mentioned above. It will provide a lot of context for you.

However, if you don't have access to that, you can also find the information in the CPT book. This excerpt is from the section for Radiation Treatment Delivery - the section that contains 77401.


:

 

[medicalauditor]

CPT 77336 is not billed for a treatment delivery course of SRT (CPT 77401). Here's an excerpt from the ASTRO Coding Resource:

View attachment 7562

Thank you so much for the information and resources provided, it does help. I did want to clarify, though, that the dermatologist does not bill both codes on the same day. What I meant to say is that the dermatologist is doing ongoing SRT and then also billing for the 77336 once per 5 fractions. So my question is - can the provider performing the SRT also be doing the medical physics consultation & billing for it themselves, or is the medical physics typically done by someone else?

 

[sls314]

Thank you so much for the information and resources provided, it does help. I did want to clarify, though, that the dermatologist does not bill both codes on the same day. What I meant to say is that the dermatologist is doing ongoing SRT and then also billing for the 77336 once per 5 fractions. So my question is - can the provider performing the SRT also be doing the medical physics consultation & billing for it themselves, or is the medical physics typically done by someone else?

The instructions from the CPT book apply to the full course of treatment, not just the date of service. 77336 should not be reported for any date of service for SRT.

To answer your other question though, 77336 is for services rendered by a medical physicist. For radiation therapy where 77336 is eligible to be billed, the radiation oncologist doesn't report it.

Typically the facility employs the medical physicist and bills the 77336 for the services of the physics staff.

 

[medicalauditor]

The instructions from the CPT book apply to the full course of treatment, not just the date of service. 77336 should not be reported for any date of service for SRT.

To answer your other question though, 77336 is for services rendered by a medical physicist. For radiation therapy where 77336 is eligible to be billed, the radiation oncologist doesn't report it.

Typically the facility employs the medical physicist and bills the 77336 for the services of the physics staff.

Got it. Thank you SO much

 

[sls314]

Got it. Thank you SO much

You're welcome!

It may help to understand what the CPT 77336 represents in case you get pushback from the dermatologist. (Of course, the CPT guidelines and the ASTRO publications are clear, but that doesn't mean you won't get push back anyhow.)

In the Continuing Medical Physics consultation (CPT 77336), a Medical Physicist is providing oversight and quality assurance for the technical aspects of the patient's treatment. They validate the dose delivery, review charts and documentation of dosimetry plans, calculations, and other items such as elapsed days, and cumulative dose.

This link from the American Association of Physicists in Medicine helps describe the scope of the profession and also the qualifications for a Medical Physicist: https://w3.aapm.org/medical_physicist/index.php

Hope this helps!

 

[medicalauditor]

You are awesome! Thank you so much. This helps. I just have one more request. Since I don't have access to ASTRO, would you be able to attach the document that you provided a snapshot of? You're right when you say it's not necessary there won't be push-back from the provider who has been billing like this forever, so having all possible resources will help. If you can't send the document to me, I understand.