January 2012 Coding Tip (View More Coding Tips and News Alerts)
IMRT MLC Devices: Are They Billable for Boost Plans?
By Tamara Syverson, BSRT (T)
With the implementation of the NCCI edit between CPT® codes 77338 and 77418, questions have been raised regarding the appropriate use of the IMRT device code for boost planning. As the boost planning, QA and corresponding fluence maps are commonly performed once the treatment course has been initiated; this has resulted in an edit between the daily treatment and IMRT device codes. While the NCCI edit designation is a “1”, which allows for the use of a modifier, assessment of the 77338 code has been necessary to ensure proper utilization.
Specified by the descriptor for the code, the device is considered billable per IMRT plan for the design and construction of the MLC based devices, unlike the IMRT plan (77301) which is considered billable one time per course. As outlined within publications by the American Medical Association (AMA) and various Medicare contractors, the explanation of the use of the 77338 code for boost planning is clearly defined.
A Coding Tip included within the CPT 2010 codebook states, “Code 77338 is reported once per IMRT plan, but it may be used more than once during an IMRT treatment course when a cone-down technique is used in the treatment plan because a new set of MLC devices are required. If a new set of MLC devices are used, a second code (77338) may be reported, but it should not be reported if a per-gantry-angle code, such as code 77334, was previously reported.”
Similarly, Medicare contractor Noridian Administrative Services indicates within the published Intensity Modulated Radiation Therapy (IMRT) LCD, “The new CPT code 77338 is used for the MLC treatment device used for IMRT. Normally it is used once per IMRT plan. In certain instances, e.g., when a radiotherapy boost is performed, it may be used more than once during a course of therapy. This CPT code 77338 is not to be used with compensator based IMRT.”
Based on these guidelines, the 77338 code is considered billable more than once per course and is applicable for circumstances such as IMRT boost planning. In addition, it is recommended to review local payer policies regarding this code and verify appropriate supporting documentation is available within the medical record.
December 2011 Coding Tip (View More Coding Tips and News Alerts)
OIG Unveils Work Plan for 2012
Teri Bedard, BA, RT(R)(T)
The Office of Inspector General (OIG) unveiled the Work Plan for Fiscal Year (FY) 2012, which runs from October 1, 2011 to September 30, 2012. The OIG was designated to maintain the integrity of the more than 300 programs under the U.S. Department of Health and Human Services (HHS), including Medicare and Medicaid. To ensure the integrity of the HHS programs, the OIG devises a work plan to detect and prevent fraud, waste and abuse. The work plan is designed to identify opportunities to improve economy, efficiency and effectiveness of the programs by holding those who do not meet the necessary requirements or violate the law accountable.
The 2012 OIG work plan includes a few items carried over from 2011 as well as a few additions potentially affecting radiation oncology. The entire work plan can be found by clicking here.
Items which could potentially apply to radiation oncology include:
- Hospital Claims with High or Excessive Payments
- Medicare Brachytherapy Reimbursement
- Critical Access Hospitals
- Physicians Place of Service Errors and Incident -To Services
- Ambulatory Surgical Centers and Hospital Outpatient Departments: Safety and Quality of Surgery and Procedures
- Evaluation and Management Services: Trends in Coding Claims and Potentially Inappropriate Payments
- Medicare Claims Review at Error Prone Providers
- Potentially Excessive Medicaid Payments and Identification and Recoupment of Improper Payments
On a semiannual basis, the OIG publishes a summary of the most significant findings from the work plan and this report is delivered to Congress in six-month increments. The recent Fall 2011 Semiannual Report indicated Medicare contractors overpaid physicians $19.3 million in 2008 and $9.5 million in 2009 for incorrect Place of Service listed on claim forms. The recent report to Congress also identified in a sampling of claims by providers that payments exceeding charges by contractors for incorrect units, codes and inadequate documentation in Jurisdictions 1, 2, 3, 8, 9 and 12 totaled over $28.7 million dollars from 2006-2009.
The work plan is a dynamic process with adjustments made throughout the year to prioritize and respond to emerging areas of focus within the programs for which the OIG provides oversight. The ability to respond depends largely on the availability of resources. Due to this, it is possible adjustments could be made to the items identified as areas of concern, proposed for review in 2012 or added in 2013.