2015 Coding Conundrums

on Monday, 12 January 2015. All News Items | Coding

Don’t Compare Apples to Oranges

Updated January 29, 2015

Motivational speakers like catchy words and phrases – remember such terms as “synergy” and “apples to apples”. Sometimes we hear these terms so much that they become irritating, but with this year’s code changes, providers have to be careful or they will be trying to correlate things that don’t go together – it’s like “apples to oranges”. Here are just a few examples.

Radiation Oncology – CPT Codes for Hospitals; HCPCS Codes for Physicians

The CPT code changes for radiation oncology for 2015 represent significant changes in how radiation therapy services and associated image guidance are reported. Since CMS decided not to pursue proposed cuts to physician radiation oncology payments, CMS created new HCPCS codes for physicians to use in reporting services for 2015 that crosswalk from the 2014 CPT codes. These codes are not for hospital reporting. The HCPCS codes G6001-G6017 are assigned a status indicator of B for OPPS. Hospitals are to report the new CPT codes for radiation oncology services.

Drug Screening Codes – HCPCS Codes for Medicare; CPT Codes for Non-Medicare Payers

Another area with major CPT code changes for 2015 is the Laboratory Drug Screening Codes. CPT deleted old codes and developed new codes based mainly on the testing methods used for analysis. Since Medicare’s HCPCS codes for drug screen tests were already based on the complexity of the laboratory testing methods, you would think these would match. Unfortunately, a direct crosswalk from CPT codes to HCPCS codes is not possible. CPT is based on the type of method (optical observation, immuno- or enzyme assay, or more complex methods). Medicare’s G codes (G0431 and G0434) are based on the testing complexity assigned by the FDA to the testing kit or analyzer – methods may fit into different complexities depending on the type of analyzer. Most hospitals are finding that selecting the new codes takes both clinical and coding expertise for correct assignment.

New Modifiers – Continue to Use 59 Modifier or Use New Modifiers

Due to concerns about the overuse and misuse of modifier 59, CMS developed new more specific modifiers available for use beginning January 1, 2015. These new X {ESPU} modifiers are a subset of modifier 59 with more specific descriptions:

  • XE –separate encounter
  • XS – separate structure
  • XP – different practitioner
  • XU – Unusual, non-overlapping service

The confusion here is whether to go ahead and use the new modifiers now or wait for further CMS guidance. There have been conflicting statements from CMS concerning this:

  • “As a default, at this time CMS will initially accept either a -59 modifier or a more selective - X{EPSU} modifier as correct coding, although the rapid migration of providers to the more selective modifiers is encouraged.” (MLN MM8863)
  • Beginning on January 1, 2015, providers canuse the X modifiers if they are currently using modifier59 for a reason within the published definition of the X modifiers. Providers also have the option to continue using modifier59 until CMSissuesexamples of circumstances in which the X modifiers are or are not appropriate.” (October 23rd Provider Connects eNews)

There are probably many more examples in the world of Medicare coding and billing of “apples to oranges” comparisons. If you think of some good examples, please share them with me at This email address is being protected from spambots. You need JavaScript enabled to view it. .

Article by Debbie Rubio

Debbie Rubio, BS, MT (ASCP), is the Manager of Regulatory Affairs and Compliance at Medical Management Plus, Inc. Debbie has over twenty-seven years of experience in healthcare including nine years as the Clinical Compliance Coordinator at a large multi-facility health system. In her current position, Debbie monitors, interprets and communicates current and upcoming regulatory and compliance issues as they relate to specific entities concerning Medicare and other payers. You may contact Debbie at This email address is being protected from spambots. You need JavaScript enabled to view it..

This material was compiled to share information. MMP, Inc. is not offering legal advice. Every reasonable effort has been taken to ensure the information is accurate and useful.

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