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Including additional scans after findings as protocol

Radiology Administrator's Compliance and Reimbursement Insider, June 1, 2007

Q: Radiologists in our department have proposed to add reporting for incidental findings to our ultrasound protocols. The topic continues to surface in a variety of situations at our facility. We've discussed incidental findings in gallstones seen with a renal study, abdominal aortic aneurysms seen in a liver study, and so forth. I was trained to image the incidental finding and make note of my impressions when reporting to the interpreting radiologist. But with so many coding changes in recent years, I am unsure whether this is an appropriate practice anymore. The radiologists have proposed a protocol change to refrain from imaging incidental findings until contacting the ordering physician for an appropriate order to evaluate the finding.

Can you clarify the rules and regulations regarding incidental-finding imaging?

A: No one likes to pay for the same meal twice. It might have tasted really good, but once it's down the gullet, it's gone. The same idea applies (in general) to imaging procedures. If you scan once, you code and bill once.

Look to the professional edition of the 2007 CPT re-quirement to document abnormalities for proof.

Parenthetical notes for abdominal ultrasound exams include the required anatomical organs or regions and end with the words "including any demonstrated abdominal abnormality."

The extent of the imaging of the abnormality provided does not matter. If you have a single image of an abnormality or create a detailed photo library, the coding remains the same.

It would also be improper to perform what, in essence, would be an additional reportable procedure (e.g., cyst on kidney turns into additional images amounting to a renal ultrasound) because of an incidental finding.

Medicare frowns on charging for additional exams that the referring physician did not order, as well as providing additional services that are not coded and/or billed.

Many physicians expand their routine protocols to include additional views.

However, additional views do not mean additional charges or codes. The number of images or views one obtains does not affect ultrasound coding.

The code selection is based on the anatomical structures visualized.

Insider source:

John Marshall, CRA, RCC, RT®, prospective payment coordinator, Sarasota Memorial Healthcare System, 2433 Huntington Avenue, Sarasota, FL 34232, 941/716-5657;john-marshall@smh.com.

Tip: Audit procedures for anti-kickback and Stark laws

According to the Office of Inspector General's (OIG) Compliance Program Guidance for Hospitals, hospitals should have policies and procedures in place to address state and federal anti-kickback statutes, as well as the Stark physician self-referral law.

Such policies should provide that the following are true:

  • All of the hospital's contracts and arrangements with referral sources comply with applicable statutes and regulations
  • The hospital does not enter into financial arrangements that are designed to provide inappropriate remuneration to the hospital in return for a hospital-based physician's providing services to federal healthcare program beneficiaries at that hospital

    Make sure that the policies and procedures address and define the OIG's safe harbor regulations, which outline payment practices that would be immune from prosecution under the anti-kickback statute.

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