As promised, this CodeMap® Radiology Briefing presents the second installment in Stacie Buck's updated discussion about the coding of fluoroscopy procedures. Today, she will conclude her analysis by reviewing the applicable provisions of the NCCI Manual. As always, if you have any questions, comments, or suggestions, please feel free to email either Ms. Buck or me.
Gregory Root, Esq.
Fluoroscopy Coding Revisited, Part 2
by: Stacie Buck, RHIA, CCS-P, RCC, CIC
President & Senior Consultant, RadRx
Now that we have an understanding of what the CPT manual and the CPT Assistant instruct concerning fluoroscopy coding, let’s take a look at what the National Correct Coding Initiative (NCCI) manual has to say.
Often coders rely on NCCI edits to direct them as to whether or not a particular CPT code is bundled with another CPT code; however, this cannot be used as the sole method for determining whether or not two codes may be reported together. This is particularly true with fluoroscopy coding.
More often than not fluoroscopy is bundled; however, in many cases there is no CCI code pair edit in place that would alert a coder that it may not be appropriate to report it. Sometimes instruction is only provided within the narrative of the NCCI manual. However, it is not uncommon for NCCI to have neither a code pair edit nor a specific set of instructions in the NCCI manual for many code combinations because it is impossible for NCCI to take into account all possible combinations. In fact, the introductory section to the NCCI manual states:
“The edits and policies do not include all possible combinations of correct coding edits or types of unbundling that exist. Providers are obligated to code correctly even if edits do not exist to prevent use of an inappropriate code combination.”
This statement places the responsibility back on the provider to ensure correct coding in the absence of a specific NCCI policy or code pair edit. It is also important to note that just because NCCI permits a modifier to be appended to bypass an edit that does not mean that it is always appropriate to do so. The circumstances of each individual case must be considered for appropriateness.
The NCCI manual reiterates some points outlined in CPT coding rules:
“If fluoroscopy is performed during an endoscopic procedure, it is integral to the procedure. This principle applies to all endoscopic procedures including, but not limited to, laparoscopy, hysteroscopy, thoracoscopy, arthroscopy, esophagoscopy, colonoscopy, other GI endoscopy, laryngoscopy, bronchoscopy, and cystourethroscopy.” (Chapters 3, 4, 5,6,7,8, 11)
“Fluoroscopy (CPT codes 76000 and 76001) is an integral component of arthroscopic procedures when performed. CPT codes 76000 and/or 76001 should not be reported separately with an arthroscopic procedure.” (Chapter 4)
There are only a few places in the entire NCCI manual where fluoroscopy is even specifically mentioned. Additionally, if you were to conduct a complete review of the code pair edits, you would find very few exist for the fluoroscopy codes. Here is a summary of those items concerning fluoroscopy outlined in the NCCI manual:
“Fluoroscopy is inherent in many radiological supervision and interpretation procedures. Unless specifically noted, fluoroscopy necessary to complete a radiologic procedure and obtain the necessary permanent radiographic record is included in the radiologic procedure and should not be reported separately.” (Chapter 9)
“Fluoroscopy reported as CPT codes 76000 or 76001 should not be reported with spinal procedures unless there is a specific CPT Manual instruction indicating that it is separately reportable. For some spinal procedures there are specific radiologic guidance codes to report in lieu of these fluoroscopy codes. For other spinal procedures, fluoroscopy is used in lieu of a more traditional intraoperative radiologic examination which is included in the operative procedure. For other spinal procedure codes, fluoroscopy is integral to the procedure.” (Chapters 4, 8)
“Fluoroscopy codes (e.g., CPT codes 76000, 76001) are not separately reportable with the procedures described by CPT codes 33202-33249 and 93600-93662. Fluoroscopy codes intended for specific procedures (e.g., CPT code 71090 for fluoroscopy during insertion of a pacemaker) may be reported separately.” (Chapters 5, 11) NOTE: The NCCI Manual instruction has not been updated to reflect the deletion of code 71090. The work previously described by 71090 (Insertion pacemaker, fluoroscopy and radiography, radiological supervision and interpretation) is now considered integral to the primary procedure. Fluoroscopy is not separately reportable with 33206-33249. In the event fluoroscopic guidance is used for diagnostic lead evaluation without insertion, replacement or revision procedures, it is appropriate to report 76000.
“Fluoroscopy reported as CPT codes 76000 or 76001 is integral to many procedures including, but not limited, to most spinal, endoscopic, and injection procedures and should not be reported separately. For some of these procedures, there are separate fluoroscopic guidance codes which may be reported separately.” (Chapter 9)
“Radiological supervision and interpretation codes include all radiological services necessary to complete the service. CPT codes for fluoroscopy/fluoroscopic guidance (e.g., 76000, 76001, 77002, 77003) or ultrasound/ultrasound guidance (e.g., 76942, 76998) should not be reported separately.” (Chapter 9)
“Radiological guidance procedures include all radiological services necessary to complete the procedure. CPT codes for fluoroscopy (e.g., 76000, 76001) should not be reported separately with a fluoroscopic guidance procedure.” (Chapter 9)
“Percutaneous coronary artery interventions (e.g., stent, atherectomy, angioplasty) include coronary artery catheterization, radiopaque dye injections, and fluoroscopic guidance. CPT codes for these procedures (e.g., 93454-93461, 76000) should not be reported separately.” (Chapter 11)
Remember, when considering whether or not to report a fluoroscopy service or fluoroscopic guidance, it is important to consider both the instruction provided in the CPT manual as well as the NCCI manual to ensure compliant coding.