Hot Off the Press!
The AARC has updated its “Coding Guidelines for Certain Respiratory Care Services” to reflect recent changes through January 2017! Based on the Medicare program’s coding and coverage policies, the AARC offers the document to assist members with “coding guidance for those respiratory care services we are asked about most frequently.” The PDF document is available to anyone via the AARC website and offers a summary of the NCCI Edits, general Medicare information, and various code regulations pertinent to respiratory care services.
Here are a few highlights:
Outpatient Only: Citing the updated introduction to the National Correct Coding Initiative, AARC’s coding guidelines document explains, right out of the gate, that: “The Centers for Medicare & Medicaid Services (CMS) developed the National Correct Coding Initiative (NCCI) to promote national correct coding methodologies and to control improper coding that leads to inappropriate payment of Part B claims.”
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Medicare Part B refers to outpatient claims. This needs to be foundational to every discussion about how these rules are applied to respiratory care services. Underscoring this fundamental understanding, the AARC document asserts that “PTP edits prevent inappropriate payment of services that should not be reported together. NCCI PTP edits are utilized by Medicare claims processing contractors to adjudicate provider claims for physician services, outpatient hospital services, and outpatient therapy services. They are not applied to facility claims for inpatient services.”
Back-to-Back: How you are reporting serial nebulizer treatments delivered in the emergency department may need to be re-evaluated according to the new regs: “If inhalation drugs are administered in a continuous treatment or a series of ‘back-to-back’ treatments exceeding one hour, CPT codes 94644 and 94645 should be reported instead of CPT code 94640.”
Episode of Care: I posted about this issue before the beginning of the new year. The NCCI update defines episode of care as follows: “An episode of care begins when a patient arrives at a facility for treatment and terminates when the patient leaves the facility.” Some may read this and falsely interpret it to mean that only one nebulizer treatment may be “billed” or worse, “administered,” during an entire inpatient stay. However, a complete review of the rule places “episode of care” clearly in an outpatient context: “If a patient receives inhalation treatment during an episode of care and returns to the facility for a second episode of care that also includes inhalation treatment on the same date of service, the inhalation treatment during the second episode of care may be reported with modifier 76 appended to CPT code 94640” (emphasis mine). The AARC guidelines rightly supply the phrase “of outpatient” into this portion of the rule. Only an outpatient returns to a facility for additional episodes of care. When inpatients do this we call it a readmission, which CMS is discouraging via punitive financial measures.
The “Coding Guidelines for Certain Respiratory Care Services” doesn’t pretend to be a comprehensive compendium of coding know-how. Indeed, the AARC disclaims: “Although this guidance is an informed opinion of respiratory therapists and advisors who are not coding specialists but have experience and knowledge of codes and coverage policies, it is always best to verify the patient’s eligibility and payer coding requirements before providing a service as benefits are subject to specific plan policies which can vary among both public and private payers.” It is a good reference, however, and certainly a great go-to document when engaging coding issues in your facility. So get your copy now!
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