Health Information Management

Q/A: Clarification of new NCCI manual language

APCs Insider, January 11, 2013

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Q: Can you clarify what this new language in the National Correct Coding Initiatives (NCCI) manual means to hospital providers?
Providers reporting services under Medicare’s outpatient hospital prospective payment system (OPPS) must report all services performed including those that are not separately payable. This requirement applies to services not payable due to NCCI edits. Providers should be careful to avoid inappropriately appending NCCI-associated modifiers to codes to improperly bypass an NCCI edit. 
A: We can answer this in very simple terms. Hospitals assign CPT codes to report outpatient services and are instructed to follow the CPT Manual guidelines and instructions when doing so. These assignments are made either through HIM or the chargemaster (CDM)—sometimes referred to as “soft” and “hard” coding. 
Regardless of whether CPT codes have a status indicator indicating they are separately payable or non-payable (packaged), facilities must accurately and compliantly assign CPT codes.
Once code assignments are complete, the NCCI edits will identify pairs of CPT codes that may be modified if applicable.
The manual language supports CMS’ long stance that facilities should report all services per coding guidelines/instructions, regardless of whether payment is generated. Facilities must appropriately use modifiers with the NCCI edits because CMS will use submitted claims data (CPT/modifiers) for future rate setting under OPPS. Maintaining the integrity of our data will ensure integrity of OPPS payments now and in the future.
Editor’s note: Denise Williams, RN, CPC-H, vice president of revenue integrity services at Health Revenue Assurance Associates, Inc., in Plantation, Fla., answered this question.

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