Another new year is approaching, and with it a new set of rules in the world of anesthesia CPT coding and documentation. The article below will act to summarize what’s new in anesthesia compliance for 2017.
The new Medicare conversion factors for 2017 are as follows:
- Anesthesia – 22.0454 (2017) versus 21.9935 (2016)
- Non-anesthesia – 35.8887 (2017) versus 35.8043 (2016)
Left Alone and Staying the Same
Not everything will change in the new year. The Centers for Medicare and Medicaid Services (CMS) and the American Medical Association (AMA) have actually managed to leave some things just as they are. For example:
- There are no new anesthesia CPT codes
- There are no modifications to the existing anesthesia CPT codes (although there is a new parenthetical comment discussed below)
- There are no changes to arterial lines, central lines, or PA catheters
- There are no changes to TEE
- There are no changes to POP block codes, except for epidurals
New CPT Comments
The 2017 CPT coding manual has added a new parenthetical comment for code 01992 indicating that one should not bill moderate sedation with 01991 or 01992 (anesthesia for chronic pain injections). Moderate sedation codes and anesthesia codes are mutually exclusive; bill one or the other, not both.
Additionally, the “Anesthesia Guidelines” section of the CPT manual contain a new comment stating that when moderate sedation is performed by a physician other than the physician performing the procedure, the physician performing moderate sedation can only bill 99155-57—if the procedure is performed in the facility. In other words, those codes are not billable in the office setting (the theory being that a second physician isn’t medically necessary in the office; and, if you need a second physician for moderate sedation, you should be in a facility). The Anesthesia Guidelines also now confirm that moderate sedation is not MAC or deep sedation.
New Epidural Codes
Deleted Codes. The 2017 CPT manual deletes the 4 iconic epidural codes (62310, 62311, 62318, and 62319). This will prove to be somewhat of a shock to those of us who have used these codes on a daily basis for nearly 2 decades now.
Replacement Codes. The new codes and descriptors set to replace the current epidural designations are as follows:
- 62320 – C/T; no fluoro; no indwelling catheter
- 62321 – C/T; w/ fluoro; no indwelling catheter
- 62322 – L/S; no fluoro; no indwelling catheter
- 62323 – L/S; w/ fluoro; no indwelling catheter
- 62324 – C/T; no fluoro; w/indwelling catheter
- 62325 – C/T; w/ fluoro; w/indwelling catheter
- 62326 – L/S; no fluoro; w/indwelling catheter
- 62327 – L/S; w/ fluoro; w/indwelling catheter
Purpose. The purpose of exchanging the 4 current codes with the 8 new codes is to distinguish between interlaminar epidurals done with, versus without, fluoroscopy.
ASA Relative Value Guide Changes
The Relative Value Guide (RVG), published by the American Society of Anesthesiologists (ASA), has revised the parenthetical comments for anesthesia codes 00600, 00604, 00620 and 00630 to clarify that these codes describe anesthesia for spinal procedures that are performed via an open or endoscopic approach. So, if the latter approach is used for a spinal procedure, the 2017 RVG indicates these 4 codes would reflect such a service. Anesthesia code 00604 identifies cervical procedures in the sitting position, and pays 13 units. Remember that parenthetical comments in the RVG are not typically present in the CPT manual; so, these comments are viewed as suggestions. They have ASA approval, but not necessarily AMA approval.
ASA Crosswalk Changes
The ASA’s 2017 Crosswalk implements the following changes to codes where the surgical definition of the code remained change. In other words, even though the surgical procedure code is the same in 2017 as it was in 2016, the ASA is changing the anesthesia code to which that procedure crosses. In most of the instances listed below, there is a change from no cross-code being listed in 2016 (because anesthesia was deemed to be not typically done or required) to a specific anesthesia CPT code being listed in 2017.
Pacemaker – Insertion of Leads or Catheters. This year, the insertion or replacement of pacemaker electrodes or pacing catheters crossed to the pacemaker code, 00530/4 units; next year, those same procedures will cross to the central venous access code, 00532/4 units.
Pacemaker – Removal of Leads or Catheters. Similarly, this year, the removal of pacemaker electrodes or pacing catheters crossed to the code for closed chest procedures, 00520/6 units, but will cross to the integumentary code, 00400/3 units in 2017.
ECMO/ECLS. Currently, the ECMO/ECLS codes do not have an anesthesia cross-code because they have been determined not to require anesthesia care. Nevertheless, beginning in January, they will cross to procedures involving arteries of upper leg, 01270/8 units.
Transabdominal Amnioinfusion; Fetal Umbilical Occlusion; Fetal Fluid Drainage. In 2016, these 3 procedures did not cross to an anesthesia code, but next year they will be reflected by the code for lower abdomen procedures, 00840/6 units.
CT Guidance – Localization, Needle Placement, and Monitoring of Radiation Therapy and Parenchymal Tissue Ablation. Though these procedures currently fall under no anesthesia codes per the ASA Crosswalk; beginning in January, they will cross to the non-invasive imaging or radiation therapy code, 01922/7 units.
Magnetic Resonance Guidance – Monitoring Parenchymal Tissue Ablation. The 2016 Crosswalk lists no anesthesia code relative to magnetic resonance guidance, monitoring of parenchymal tissue ablation. The 2017 Crosswalk crosses this procedure to the non-invasive imaging or radiation therapy code, 01922/7 units.
CT – Bone Mineral Density Study. Currently, the CT, bone mineral density study, 1 or more sites, axial skeleton procedure does not have an anesthesia code. In 2017, it crosses to the non-invasive imaging or radiation therapy code, 01922/7 units.
MRI – Bone Marrow Blood Supply. In 2016, the MRI for bone marrow blood supply has no anesthesia code. However, beginning in January, it will cross to the non-invasive imaging or radiation therapy code, 01922/7 units.
Ophthalmological Exam and Evaluation Under General Anesthesia. Currently, the ophthalmological examinations and evaluations under general anesthesia crossed to the ophthalmoscopy code, 00148/4 units. Next year, they will cross to the code reflecting anesthesia for procedures on the eye, not otherwise specified, 00140/5 units.
Auditory Brainstem Response – Comprehensive or Limited. This year (2016), the auditory evoked potentials for evoked response audiometry and/or testing of central nervous system did not have an anesthesia cross-code; next year, it will cross to the integumentary system code, 00300/5 units.
Otoacoustic Emissions – Comprehensive or Limited. Currently, the otoacoustic emissions procedures do not have an anesthesia cross-code; Beginning in 2017, these procedures will cross to the integumentary system code, 00300/5 units.
FCA Penalties Double for Inflation
The Inflation Adjustment Act has ushered in an increase in FCA penalties from what was originally $10,000 per false claim (and which subsequently increased to $11,000 per false claim) to now $21,563 per false claim or kickback violation.
Base Unit Values for 00810 and 00740 Unchanged
CMS is still considering, but has yet to implement, the lowering of the anesthesia base units for GI procedures (due to the fact that so many GI procedures are done under anesthesia). The base unit value for these services remains at 5.
Fluoroscopy: 77003, 77002, and 77001
Global Periods. Services reflected by codes 77001-77003 will now have the same global period as the underlying procedure.
Add-on Codes. CPT 77002 and 77003 are now designated as add-on codes. The “+” adjacent to 77002 and 77003 in the CPT manual means these codes can only be billed with another code (this doesn’t change anything for anesthesia since that is how we’ve always billed these codes).
Interlaminar Epidurals Cannot be Billed with 77003. Last year, the CPT manual allowed 77003 with interlaminar epidurals (Medicare did not). This year, 77003 will not be billed with any epidural codes, because the use of fluoroscopy with interlaminar epidurals is built into the new epidural codes.
QMBs (Qualified Medicare Beneficiaries)
The 2017 Medicare Physician Fee Schedule (MPFS) Final Rule reminds providers that they cannot balance bill a Medicare beneficiary who also has Medicaid under the QMB program, other than billing any co-pay that Medicaid reflects is owed on its EOB. Medicare suggests verifying QMB status with Medicaid.
The Final Rule also states that a provider must be enrolled in Medicare Part B to participate in Medicare Advantage (Part C).
New Anti-Discrimination Rule (ACA Section 1557) – Translation Services
Primary Provisions. Providers are now required to provide free translation services to patients who are not proficient in the English language. Each group must post a notice of nondiscrimination relating to people who cannot adequately speak the English language. The Office of Civil Rights (OCR) has published a form that you can use for the notice. The notice must also contain a “tagline” in the 15 most prevalently spoken languages in your particular state. The OCR has published the top 15 languages spoken in each state, and has also published the taglines in those languages. If you have 15 or more employees, you must develop a language access plan, appoint a compliance officer, and develop grievance procedures for patient complaints. You must also submit HHS Form 690 attesting to compliance.
Applicability. These rules apply if you accept Medicaid or any government assistance. If you do not accept Medicaid, or any other federal assistance, these new rules do not apply to you.
PHI in the Cloud
The OCR released guidance stating that if you store electronic protected health information (ePHI) in the cloud, you must have a business associate agreement (BAA) with the cloud service provider (CSP)—even if that CSP does not store your encryption key and cannot view your data, but only stores the ePHI.
2017 OIG Work Plan
Each year, the Office of Inspector General (OIG) publishes a list of target areas it plans to investigate in the coming year. This list is called a “Work Plan.” The 2017 Work Plan includes the following two items relating to anesthesia:
Medically Unnecessary Anesthesia Services. The OIG will review whether or not anesthesia was provided for non-covered services (such as cosmetics), procedures which are not medically necessary, or anesthesia that is not medically necessary. If an underlying surgery is either investigational or not medically necessary, the anesthesia is considered not medically necessary.
Payment for Personally Performed Services. Audits will determine if providers are billing the AA modifier (personally performed) where the anesthesia should have been billed as QK (medically directed). This is primarily directed at teaching institutions which have residents and are billing residents as personally performed, when in fact the teaching anesthesiologist was not present during all critical events.
Is your 2017 billing and coding up to date? Contact our anesthesia business consultants today!
I wish to thank Baton Rouge healthcare attorney David Vaughn for providing the bulk of the above information.
• MEDAC – Committed to Continuing Client Education •
The information presented herein reflects general information that is current as of the date it was first published. In light of changes that may occur in the health care regulatory and compliance environments, the author’s presentation of this information might become outdated. Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.