Knowledge Base Category -

Q:

During a procedure when only one or two lymph nodes are removed; would the correct “Root Operation” be “Resection” or “Excision”?

A:

Lymph nodes are known to form together in clusters, better known as a “chain of nodes”. There are generally numerous amounts of lymph nodes within a chain of nodes. It can be difficult to know for sure whether all nodes were removed or not during any one particular procedure. One example of this would be when a patient is extremely obese.

Assign root operation “Resection”:

• When all nodes in a chain are removed.
• When total removal of lymph nodes is the physician’s intent but difficult to determine if they have actually all been removed.

Assign root operation “Excision”:

• When only a partial amount of lymph nodes are removed from the chain.

Assign root operation “Excision”:

• Sampling of nodes removed – example would be Sentinel Nodes

The operative report should be read carefully to determine the exact intent for the lymph node removal.

References Coding Clinic 3rd Quarter 2014 (ICD-10-CM/PCS) pages 9 and 10

Q:

How do you report the quantity of a drug with a HCPCS code when the HCPCS dose is different from the dose that was given?

A:

You can round up the quantity when needed with any of the drug HCPCS codes.

So if the HCPCS code is “per 5 MG” and you gave 10 MG, you would report the HCPCS code with a quantity of 2. If the HCPCS code is “per 5 MG” and gave 8 MG, you would round up and report the HCPCS code with a quantity of 2.

Reference: Medicare Claims Processing Manual, chapter 17, section 10

“Hospitals must report all appropriate HCPCS codes and charges for separately payable drugs, in addition to reporting the applicable drug administration codes. Hospitals should also report the HCPCS codes and charges for drugs that are packaged into payments for the corresponding drug administration or other separately payable services. Historical hospital cost data may assist with future payment packaging decisions for such drugs. Drugs are billed in multiples of the dosage specified in the HCPCS code long descriptor. If the drug dose used in the care of a patient is not a multiple of the HCPCS code dosage descriptor, the provider rounds to the next highest unit based on the HCPCS long descriptor for the code in order to report the dose provided. If the full dosage provided is less than the dosage for the HCPCS code descriptor specifying the minimum dosage for the drug, the provider reports one unit of the HCPCS code for the minimum dosage amount.”

Q:

What is the KX modifier and when should it be used?

A:

The KX modifier is defined as “Requirements specified in the medical policy have been met.” It is a multipurpose informational modifier.

CMS has further defined some specific circumstances when providers should report the KX modifier.

• To report an automatic exception to therapy caps. Adding the KX modifier to the line items that exceed the therapy caps indicates that the clinician attests that services at and above the therapy caps are medically necessary and justification is documented in the medical record.
• When billing for permanent cardiac pacemakers under the latest NCD revision effective August 13, 2013. Appending the KX modifier is an attestation by the provider that documentation is on file verifying the patient has non-reversible symptomatic bradycardia.
• To bill additional optional sessions of cardiac rehab or pulmonary rehab. Medicare allows 36 sessions, with the option for an additional 36 sessions for each of these services. Sessions beyond the initial 36 sessions, up to 72 sessions, require the KX modifier.
• To report FDG PET scans for subsequent treatment strategy beyond the 3rd scan. Each different cancer diagnosis is allowed one (1) initial treatment strategy (-PI modifier) FDG PET Scan and three (3) subsequent treatment strategy (-PS modifier) FDG PET Scans without the -KX modifier. The fourth FDG PET Scan and beyond for subsequent treatment strategy for the same cancer diagnosis will always require the -KX modifier.
• On MRIs for patients with implanted pacemakers that are FDA-approved for use in an MRI environment.Inclusion of the KX modifier on the claim line(s) means that the provider attests that documentation is on file verifying that FDA-approved labeling requirements are met.

Q:

What should we do when Acute Respiratory Failure is documented but the clinical signs and symptoms describing the patient do not reflect the severity of the diagnosis?

A:

Coders in this day and time have to know and be aware of more clinical factors than ever before. Look at the patient’s clinical presentation and what tests are performed. Below is a listing of just a few basic things MMP suggests looking for:

1.Documented signs / symptoms

• SOB (shortness of breath) / Respiratory distress
• Delirium and/or anxiety
• Pursed lips
• Syncope
• Use of accessory muscles
• Tachycardia
• Tachypnea
• Confusion
• Sleepiness
• Depressed consciousness
• Cyanosis (bluish color to skin, lips and/or fingernails)

2.Per Coding Clinic, Acute Respiratory Failure is supported as a diagnosis when at least 2 of the following critical values (ABG’s) are met.

• pH < 7.35
• PO2 < 60
• PCO2 > 50

Note: The above ABG levels may not apply to the patient with chronic lung disease (e.g., COPD). If a baseline PO2 is known, a decrease by 10mmHg or more indicates acute Hypoxic Respiratory Failure.

3.Type of oxygen treatment, i.e., oxygen via mask, Bipap, nasal cannula or vent?

4.Generally, patients are placed in ICU for close monitoring.

MMP recommends coding Acute Respiratory Failure if there are sufficient clinical indications and the physician has documented the diagnosis. Most importantly, if you don’t see sufficient clinical signs/symptoms/indicators documented, the physician should be queried for clarification. It is recommended that all clinical indications in the record and the type of treatment the patient received, be documented in the physician query.

Q:

Have the Medicare coverage requirements for pneumococcal vaccinations changed?

A:

Yes, the Advisory Committee on Immunization Practices (ACIP) has issued new recommendations for pneumococcal vaccinations and Medicare has modified their coverage requirements in response to the new recommendations.

As announced in MLN Matters Article MM9051, effective for dates of service on and after September 19, 2014, Medicare will cover the administration of two different pneumococcal vaccinations.

• An initial pneumococcal vaccine to all Medicare beneficiaries who have not previously received a vaccine (based on ACIP recommendations a 13-valent pneumococcal conjugate vaccine – PCV13 should be administered first)
• Followed by a second, different vaccine a year later (23-valent pneumococcal polysaccharide vaccine – PPSV23)

Patients, age 65 and older, who have already received the PPSV23 vaccine, should receive the PCV13 vaccine a year or more after the date of their last PPSV23 vaccine.

These new guidelines differ from the previous coverage of pneumococcal vaccine which was only for individuals at high risk of serious pneumococcal disease (age 65 and older, risk from chronic disease, or immune-compromised patients) with a repeat vaccine after five years for only patients at highest risk (May 1, 1981- September 18, 2014).

Note that a physician’s order is not required for patients to obtain a pneumococcal vaccine.

Q:

How should laceration repairs by steri-strips or dermabond be coded?

A:

According to the CPT manual a wound closure/repair with adhesive strips as the sole repair material are not reported with a separate CPT code but as part of the evaluation and management (E/M service). This means that laceration repairs performed in the Emergency Department using only steri-strips would be included as part of the determination of the ED visit level.

For tissue adhesives, which would include dermabond, you can report a CPT code from the repair section.

This guidance is in the first paragraph under the ‘Repair (Closure)’ section in the CPT book. The complete paragraph reads:

“Use the codes in this section [CPT codes 12001-13160] to designate wound closure utilizing sutures, staples, or tissue adhesives (eg, 2-cyanoacrylate), either singly or in combination with each other, or in combination with adhesive strips. Wound closure utilizing adhesive strips as the sole repair material should be coded using the appropriate E/M code.”

Q:

Sometimes a physician may dilate more than one stricture during an endoscopy procedure. Should we code the dilation of each stricture?

A:

The answer depends on the patient’s insurance because CPT and the NCCI manual provide different coding instructions.

Effective January 2015, CPT guidance allows the reporting of each stricture dilated utilizing modifier 59. Parenthetical notes for CPT codes 43213, 45340, and 45386 state, “For transendoscopic balloon dilation of multiple strictures during the same session, report ‘code’ (43213, 45340, or 45386) with modifier 59 for each additional stricture dilated.”

The National Correct Coding Initiative (NCCI) Policy manual guidance applies to coding and billing for Medicare and Medicaid claims. The 2015 NCCI manual update includes this instruction concerning dilation of multiple strictures:

“Gastrointestinal endoscopy CPT codes describing dilation of stricture(s) (e.g., CPT codes 43213, 45340, 45386) include dilation of all strictures dilated during the endoscopic procedure. These codes should not be reported with more than one (1) unit of service if more than one stricture is dilated.”

Other insurers may choose to follow some of the NCCI coding guidance. Check with the payer to determine their policy regarding these instructions.

Q:
What does Medicare expect from providers concerning limiting drug wastage? For example, if a chemo drug comes in two sizes of single-dose vials, 100 mg and 160 mg and the patient’s dose is 237 mg, could we use three 100mg vials with a wastage of 63 mg, or must we use one 100mg and one 160mg vial for the least amount of wastage (23mg)? 

A:

The Medicare Claims Processing Manual, Chapter 17, section 40 states, “The CMS encourages physicians, hospitals and other providers and suppliers to care for and administer to patients in such a way that they can use drugs or biologicals most efficiently, in a clinically appropriate manner.”

Medicare is generally not concerned if you have to jump through extra hoops in order to comply with their guidelines.

Since…

• This drug is separately reimbursed by Medicare
• Medicare has done targeted reviews of some of the other chemo drugs specific to waste issues
• Medicare has instructed hospitals how to report drug waste

 ……MMP recommends you try to minimize waste, even if it involves extra steps.

If you have only the 100 MG dose vials available, then you use what you have. In this case, you are allowed to bill the waste as long as there is not another patient getting the same drug for which the unused portion could have been used.

If you are reviewed by a Medicare reviewer, and they question your billing, you might have to provide invoices, or other documentation proving why you billed as you did.  

Q:

Where can I find the new QIO contact information that we should put on the Important Message from Medicare (IM) letter?

A:

As of August 1st, the QIO Program began its 11th Scope of Work (SOW). The newly created Beneficiary and Family Centered Care – Quality Improvement Organizations (BFCC-QIOs) are responsible for managing discharge appeals.

There are two BFCC-QIOs for the nation. CMS awarded the two BFCC-QIOs contracts to Livanta, LLC located in Annapolis Junction, Maryland and KePRO located in Seven Hills Ohio. The 50 states, DC, Puerto Rico and the Virgin Islands have been divided into Five (5) Areas.

CMS has provided a 2014 QIO Program Transition Fact Sheet for Providers and Suppliers. In this fact sheet CMS instructs Providers that a list of current BFCC-QIOs as well as the Quality Innovation Network (QIN) QIOs can be found at http://www.qioprogram.org under Locate Your QIO.

Q:

How do you determine the level of physician supervision required for hospital outpatient therapeutic and diagnostic services?

A:

The answer is sort of like putting together a jigsaw puzzle. There is a piece here and a piece there. Terms defined in one place, then defined further in another place, codes in the physician RVU file, and a new type of service supervision designation altogether. Let’s see if we can put the pieces in place.

Definitions

Definitions of the levels of supervision can be found in the Code of Federal Regulations at 42 CFR 410.32 (b).

• General supervision means the procedure is furnished under the physician's overall direction and control, but the physician's presence is not required during the performance of the procedure.
• Direct supervision in the office setting means the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician must be present in the room when the procedure is performed. CMS has further defined direct supervision for services provided in a hospital in the Medicare Benefit Policy manual, chapter 6, sections 20.4 and 20.5 as noted below.
• Personal supervision means a physician must be in attendance in the room during the performance of the procedure.

This section of the CFR also discusses some exceptions to diagnostic supervision requirements such as mammography services, audiology tests, laboratory tests, and a few other exceptions.

In the Medicare Benefit Policy manual, CMS clarifies the definition of “direct supervision” as it relates to hospital services performed during or after CY 2011 – “whether directly or under arrangement in the hospital or in an on-campus or off-campus outpatient department of the hospital as defined at 42 CFR 413.65, “direct supervision” means that the physician must be immediately available to furnish assistance and direction throughout the performance of the procedure. As discussed below, the physician is not required to be present in the room where the procedure is being performed or within any other physical boundary as long as he or she is immediately available…. Immediate availability requires the immediate physical presence of the supervisory physician. CMS has not specifically defined the word “immediate” in terms of time or distance; however, an example of a lack of immediate availability would be situations where the supervisory physician is performing another procedure or service that he or she could not interrupt. Also, for services furnished on-campus, the supervisory physician may not be so physically distant on-campus from the location where hospital outpatient services are being furnished that he or she could not intervene right away. The hospital or supervisory physician must judge the supervisory physician’s relative location to ensure that he or she is immediately available… The supervisory physician must have, within his or her State scope of practice and hospital-granted privileges, the knowledge, skills, ability, and privileges to perform the service or procedure… The supervisory responsibility is more than the capacity to respond to an emergency, and includes the ability to take over performance of a procedure or provide additional orders.”

Hospital Outpatient Diagnostic Services

The supervision requirements for hospital outpatient diagnostic services can be found in the Medicare Benefit Policy manual, chapter 6, section 20.4. Section 20.4.4 explains that supervision levels for individual diagnostic tests are listed in the quarterly updated Medicare Physician Fee Schedule (PFS) Relative Value File which can be found on the Medicare Physician RVU File webpage. After selecting the year and quarter (quarters identified by A (January), B (April), C (July), etc.), download the zip files, select the PPRRUV14 spreadsheet and locate the “Physician Supervision of Diagnostic Procedures” column (column Z in this year’s spreadsheets). Hospitals are interested in the designation for the technical component (TC) of diagnostic services. The supervision levels are listed by codes, the definitions of which can be found in the Medicare Benefit Policy manual, chapter 15, section 80. The main designations are:

• 1 - Procedure must be performed under the general supervision of a physician.
• 2 - Procedure must be performed under the direct supervision of a physician.
• 3 - Procedure must be performed under the personal supervision of a physician.
• 9 - Concept does not apply.

Certain diagnostic tests performed personally by non-physician practitioners (NPPs) do not require physician supervision but NPPs may not supervise diagnostic tests when performed by other hospital staff.

Hospital Outpatient Therapeutic Services

Section 20.5.2 of chapter 6 of the Benefit Policy Manual describes the supervision requirements for therapeutic services - all therapeutic services provided to hospital outpatients generally require direct supervision by an appropriate physician or NPP although CMS may assign a different level of supervision to some therapeutic services. In addition to physicians and clinical psychologists, licensed clinical social workers, physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse-midwives may furnish the required supervision of hospital outpatient therapeutic services that they may personally furnish in accordance with State law and all additional rules governing the provision of their services. However, pulmonary and cardiac rehab services require that a physician provide the direct supervision.

CMS may designate certain services to general or personal supervision or beginning in 2011, as non-surgical extended duration therapeutic services. Extended duration services require direct supervision during the initiation of the service followed by general supervision for the remainder of the service at the discretion of the supervising practitioner. The service can transition to general supervision after the beginning portion of the service when the supervising practitioner decides the patient is stable enough for general supervision. The point of transition to general supervision must be documented in the patient’s progress notes or medical record. A list of “Hospital Outpatient Therapeutic Services Designated as General or NSEDTS” is available in the downloads section on the Hospital OPPS webpage.