NCCI offers update on reporting inhalation treatments
APCs Insider, May 16, 2014
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By Steven Andrews, Editor
A January 2014 change to the NCCI Coding Policy Manual that limits how many inhalation treatments can be reported per encounter, which was not noted in the 2014 CPT® Manual or mentioned in the 2014 OPPS Final Rule, has been a source of confusion for providers.
The update involves code 94640 (pressurized or nonpressurized inhalation treatment for acute airway obstruction or for sputum induction for diagnostic purposes [e.g., with an aerosol generator, nebulizer, metered dose inhaler, or intermittent positive pressure breathing device]).
Chapter XI, Section J, Number 8, the January 2014 NCCI update states:
CPT code 94640 should only be reported once during a single patient encounter regardless of the number of separate inhalation treatments that are administered. If CPT code 94640 is used for treatment of acute airway obstruction, spirometry measurements before and/or after the treatment(s) should not be reported separately. It is a misuse of CPT code 94060 [bronchodilation responsiveness, spirometry, pre- and post-bronchodilator administration] to report it in addition to CPT code 94640. The inhaled medication may be reported separately.
These treatments are used very frequently during observation stays, according to Valerie A. Rinkle, MPA, associate director with Navigant Consulting in Seattle. "Patients with shortness of breath or COPD are often given four or five treatments per day, which have always been billed per individual treatment and paid under OPPS per individual treatment."
According to a statement by Linda Dietz, RHIA, CCS, CCS-P, coding specialist for NCCI, the treatment can only be reported once per encounter, but providers may have multiple, separate encounters with the same patient throughout the day. Dietz says:
There is some confusion about the definition of "encounter" as used in this paragraph when applied to an outpatient hospital site of service. The Internet Only Manual, Medicare Claims Processing Manual, Publication 100-04, Chapter 2, Section 90.6 (Definition of Encounter) defines an encounter as "direct personal contact in the hospital between a patient and a physician who is authorized by State law and, if applicable, by hospital staff bylaws to order or furnish services for diagnosis or treatment of the patient."
Applying this definition to Chapter XI, Section J, Paragraph 8 of the NCCI Manual, the provider may only report one (1) unit of service (UOS) for a professional's (e.g., respiratory therapist) visit to provide services reported as CPT code 94640 even if those services require more than one inhalation treatment (e.g., multiple medications) at that encounter. The professional does not have to provide continuous face-to-face service during the entire treatment time but may initiate the inhalation treatment and return to continue or complete it. If the professional completes the inhalation service(s) and terminates the patient encounter but returns later that day to initiate additional inhalation treatment(s) reportable as CPT code 94640, an additional UOS of CPT code 94640 may be reported for this subsequent patient encounter.
Providers should confirm this change with their Medicare contractors and commercial payers to ensure they're following the latest guidelines.
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