CMS Reverses View on Bundling 77300 Into 77290

On January 5, 2016 in the medical billing blog titled “Radiation Oncology Billing – An Ever Moving Target” we talked about numerous CMS radiation oncology coding changes. One of the more financially negative ones was the implementation of a NCCI edit effecting 3D radiation therapy treatment planning. CPT code 77295 was going to include the basic dosimetry calculation(s) represented by CPT code 77300.

reversal of NCCI eidt    
     However, just last week there was a welcome announcement. After months of work by ASTRO
     to convince CMS that this bundle was inappropriate, their appeal was successful.  On July 1,
     2016 the edit will be deleted in the NCCI Manual. Even though the change is effective July 1,
     they are making it retroactive to January 1, 2016.  

     What does that mean for your radiation oncology practice?  This is going to depend on how
     you adjusted your billing policy for Codes 77295 and 77300 back in January.  Some practices
                        observed the NCCI edit across the board for all payers, while some continued to bill
                        commercial payers for the 77300.
timely filing guidelines

 

With Medicare and Medicaid you have up to one year from the date of service to submit charges, so submitting of the retroactive 77300’s will not be denied due to timely filing guidelines.

Commercial payers however can have relatively short timelines, 60 to 90 days.  Based on this, it is probably a good idea to bill out the 77300’s now.  If they are denied, you will be set up for appeal when July comes around.

 

For Iridium Suite medical practice software users, here’s a suggestion to help you find the 77300s to bill (Click here for a free demo of Iridium Suite):

1.       Go to Report Center>Accounts Receivables>Service Line Search Report>Select Date of Service:
          01/01/2016 to present date> CPT code constraint: 77295.

 

2.       For each patient listed with code 77295, open the Patient Chart CPT Capture screen, you can verify that
          77300 was not billed.

 

3.       Go to the Medical Record to determine the proper number of units to bill for 77300 and enter this in the
          CPT Capture screen.

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     It isn’t often a sweeping financial decision by CMS is reversed and relatively quickly as well. 
     Radiation Oncology providers were definitely lucky this time around!