Industry News, September 2020

The summary of events and newsworthy items for the month of September is provided on the following pages.  In most instances, the link to the full document of information is provided.  Any of the contents may be further discussed by reaching out to Revenue Cycle Coding Strategies LLC.

RO Model Final Ruling Released

The Centers for Medicare and Medicaid Services (CMS) issued the final rule for the Radiation Oncology Model (RO Model) on September 18, 2020. The RO Model will go into effect January 1, 2021 for the mandatory participants. RCCS has summarized the RO Model and a copy can be obtained upon request.  As additional resources and information are released from CMS notifications will be sent out.

The CY 2021 final rule from CMS can be located, in its entirety, here. Additionally, CMS has created a website dedicated solely to the RO Model where they will be posting updates and information for providers. There are also helpful links on the dedicated website such as a fact sheet and participating zip code list, among other resources.

Imaging Use in COVID-19 Varies Across Globe, Survey Finds

A survey released earlier this month shows there is disparity in imaging modalities used to evaluate COVID-19 across the world, although most institutions are avoiding imaging studies in asymptomatic patients, experts report.

There has been disagreement in the radiology community since the pandemic began regarding the merits and efficacy of using imaging to diagnose COVID-19.  In China, scientists have extolled the virtues of using CT to assess the disease, but major imaging societies in the U.S. and U.K. have advised against this method. The survey, conducted jointly by the International Society of Radiology and the European Society of Radiology, was shared Thursday in European Radiology. It reflects responses from 50 radiology departments in 33 countries across all continents.  Experts hope the findings will help identify discrepancies in how imaging is used to assess COVID-19 and assist radiology departments in developing modified imaging protocols for use during this and future pandemics. 

Most survey respondents (69%) stated they typically do not perform imaging on asymptomatic patients, but 60% of institutions said they used imaging at the end of confinement. Across the world, chest imaging is being used to evaluate patients with suspected (89%) or confirmed (94%) disease.  Modality type varies for each clinical scenario. The study also found that 98% of institutions applied use of imaging in line with existing guidelines and recommendations, with 58% of institutions performing structured reporting. Perhaps unsurprisingly, 83% of institutions reported a significant impact on their imaging department’s routine activity as a result of the COVID-19 pandemic.

It is obvious that the practice of imaging in COVID-19 differs throughout the world, especially regarding the utilization of conventional chest x-ray and computed tomography,” wrote Ivana Blažić & colleagues with the Radiology Department at the Clinical Center of Serbia. “We believe that the results of this survey will help to understand current practice heterogeneities and to identify needs and gaps in the organization and function of radiology departments worldwide in relation to the COVID-19 pandemic.”

To read the survey in its entirety, click here.

AMA Releases New CPT Code to Report Additional COVID-19 Costs

In response to the Public Health Emergency declared on January 31, 2020 because of the COVID-19 pandemic, the AMA released a new Category I CPT® code to describe additional resources required to treat patients during a PHE. CPT® 99072 was released on September 8, 2020 for immediate use. This code accounts for increased practice expenses incurred due to a Public Health Emergency and is specific to respiratory-transmitted infectious diseases. This code should be used (in addition to the code for the in-person patient encounter for an office visit or other non-facility service) to report additional supplies, materials, and clinical staff time required to prevent the spread of communicable disease during a PHE (i.e. when declared by law by the officially designated relevant public health authority(ies). 

“This update is the latest in a series of modifications to the CPT codes set to meet the needs of the healthcare industry as medical advancements expand the fight against COVID-19,” AMA President Susan Bailey, MD, said in a statement.  

Examples of services and supplies that may be represented by this new code include:

  • Preliminary screening for relevant patient symptoms by phone and/or in-person
  • Providing instructions on social distancing during the visit
  • Donning and removing personal protective equipment, or PPE (over and above what is usually required for a patient visit or service)
  • Increased sanitation measures

Per CPT® Assistant Special Edition September 2020, “This new code should only be reported when the service is rendered in a non-facility place of service (POS) setting, and in an area where it is required to mitigate the transmission of the respiratory disease for which the PHE was declared.” A list of POS codes and their designations as facility or non-facility can be found in the Medicare Claims Processing Manual at

Code 99072 is to be reported only once per in-person encounter per PIN (provider identification number), regardless of the number of services rendered during the encounter.  CPT® Assistant states that “In the instance in which the noted clinical staff activities are performed by a physician or other qualified health care professional (eg, in practice environments without clinical staff or a shortage of available staff), the activity requirements of this code would be considered as having been met; however, the time spent should not be counted in any other time-based visit or service reported during the same encounter.”

Use of this code is not dependent on a specific diagnosis. Under HOPPS, 99072 has a status indicator of B, indicating that it is not recognized by OPPS when submitted on an outpatient bill and is therefore not paid under OPPS. Documentation requirements for 99072 may vary by payer; contact the individual payer to determine their specifications. 

Please click here and here for additional coding and reimbursement information about code 99072.  

Executive Order Aimed at Lowering Drug Prices

On September 13, 2020, a newly signed executive order replaced and expanded upon a July executive order which aims at lowering drug prices for the United States. The July order required Medicare to tie the prices it pays for drugs to those paid by other countries. The new executive order seeks to expand upon the July order but continues to focus on lowering drug prices in the United States by linking them to those of other nations. The new order also extends the mandate to prescription drugs available at a pharmacy where the July version focused mostly on drugs administered in the doctors’ offices and health clinics. While the order has been signed, there will have to be an issuance of new federal rules and a process to determine prices paid by other countries before implementation of the new, lower drug prices. The executive order can be read here.

WPS Identifies Signature Errors

Medicare Administrative Contractor, WPS has been made aware of error findings for missing or illegible physician and non-physician signatures on medical record documentation following claims reviews performed by the Comprehensive Error Rate Testing (CERT) contractor. It was noted that the performing physician did not sign their medical record documentation in accordance with Medicare regulations. WPS included four signature reminders:

  • If the CERT contractor requests an attestation statement, do not resubmit medical record documentation with a signature added. You must send an attestation statement as requested.
  • The CERT contractor will accept an attestation statement if the performing provider’s signature is missing from a progress note supporting intent.
  • You can submit an attestation statement or a signature log if the provider’s signature is illegible.
  • Do not use an attestation statement to show intent when the physician orders and laboratory requisition form is unsigned. The physician or non-physician signed progress note must clearly document the intent to order the test.

More information regarding CMS signature regulations can be found in the CMS Internet-Only Manual, Publication 100-08, Chapter 3, Section Requirements, as well as within the article Signature Guidelines for Medical Review Purposes.

September Coding Corner

Within this section, current topics will be the focus. In some cases, the Q&A could reflect common questions received by Revenue Cycle Coding Strategies and in other cases, represent current issues encountered by Revenue Cycle Coding Strategies professionals.

Question: I would like to confirm that a Dentist can charge 77334 for a custom mouth guard device used to treat head and neck patients with radiation therapy.

Advice: If the custom mouth guard is created at the dentist’s office, the dental office would bill for their services and device using their designated codes specific to the dental office. If the custom mouth guard is purchased by your department from the dental office and created and used as part of the simulation process, then 77334 by your department could be captured.

Question: We have SBRT patient for 3 fractions. Can we report 77336 with 77373 on the same date of service?

Advice: Yes, code 77336 can be billed on same date as 77373.

Follow-up Question: How would we appeal if we get denial from MCR that payment for 77336 is bundled into CPT® 77373? Is it appropriate if modifier 59 is applied to CPT® 77336?

Follow-up Advice: I would appeal and ask for the guidance used to state 77336 is bundled. If this is Medicare, they state 77336 is included in the following services, “Continuing medical physics consultation (CPT® code 77336) is reported “per week of therapy.” It may be reported after every five radiation treatments. (It may also be reported if the total number of radiation treatments in a course of radiation therapy is less than five.) Since radiation planning procedures (CPT® codes 77261-77334) are generally performed before radiation treatment commences, the NCCI contains edits preventing payment of CPT® code 77336 with CPT® codes 77261-77295, 77301-77318, and 77332-77334. Because radiation planning procedures may occasionally be repeated during a course of radiation treatment, the edits allow modifiers 59 or -{EPSU} to be appended to CPT® code 77336 when the radiation planning procedure and continuing medical physics consultation are reported on the same date of service.” There is no edit with 77373, if it were billed on same date as treatment planning then modifier 59 could be applied, but if there are no edits then a modifier is not applied.