Alfred H. Moffett, MD, FACOG
Immediate Past Chair and Medicare Liaison
Medicare Liaison Report
The following information is from James Corcoran, MD, MPH, Chief Medical Director of First Coast Service Options (FCSO) Inc.
Procedures Utilizing a Vaginal Approach (Hysterectomy Bundling):
Effective October 1, 2014, the Centers for Medicare and Medicaid Services (CMS) began permanently bundling anterior/posterior colporrhaphy and colpopexy procedures into all vaginal and laparoscopic-assisted hysterectomy codes. Per the chart developed, while working through this process with CMS and the sub-speciality societies, there were four laprascopic hysterectomy codes listed, (58550-58554) and a new permanent bundle with colpopexy code 57282. The April 2015 NCCI Edits revised the bundle from “never paid” to “may be paid”.
The American Congress of Obstetricians and Gynecologists (ACOG) and the American Urogynecologic Society (AUGS) wrote to CMS in May with regard to these edits and objected to them strongly. The edits were rescinded in 2015, although some now require modifiers in order to be reimbursed. The current plan as discussed by ACOG and the other sub-specialities is to move forward to develop new codes that bundle these services rather than attempt to have them eliminated altogether. These organizations will continue to work with CMS to get them removed. Until then, physicians who perform anterior/posterior colporrhaphy and colpopexy procedures with a vaginal or laparoscopic-assisted hysterectomy will need to clearly make a case in the operative report for the need to perform the additional procedures in order to add a modifier -22 (increased procedural services) to the hysterectomy code for consideration of additional payment. Based on the April rescission of the edits, we recommend reporting both services when appropriate, and appending modifier -59 (distinct procedural services) to the A&P repair code. If an A&P repair is performed, it would not be appropriate to bill only an anterior repair (CPT code 57240) or a posterior repair (CPT code 57250) to obtain some separate reimbursement, as this would represent inaccurate coding.
ACOG has worked closely with CMS and the National Correct Coding Initiative (NCCI) and the specialties listed below on correcting the TVH CCI edits. Although Medicare has rescinded some of the edits, other edits remain but can be bypassed with a modifier. The following is the message that went out to all members in March.
On January 27, 2015 CMS notified ACOG that the some of the CCI "Edits for Procedures of the Uterus and for Procedures Utilizing a Vaginal Approach" that became effective on October 1, 2014 would be rescinded in CCI version 21.1on April 1, 2015. Other codes pairs will be eligible for bypass with a modifier. The changes will be retroactive to October 1, 2014.
Specifically, these edits apply to vaginal hysterectomy codes when they are billed with vaginal reconstruction codes.
Although the NCCI vaginal hysterectomy code edits that took effect on October 1, 2014 are currently still active, ACOG recommends that you start working with your billing departments now to identify the claims that will be eligible for resubmission on April 1.
Currently, many of these CCI edits will require the use of a modifier. As a result, the ACOG Coding Committee suggests that you verify correct coding including modifiers and ensure that your work is thoroughly and completely documented to help ensure clean claims processing.
ACOG, the American Urogynecologic Society (AUGS), the American Urological Association (AUA), Society of Gynecologic Surgeons (SGS), the International Urogynecological Association (IUGA), and the Society of Urodynamics, Female Pelvic Medicine & Urogenital Reconstruction (SUFU) have been working together to correct these inappropriate CCI edits through an ongoing series of letters and calls with CMS and their contractor, the National Correct Coding Initiative (NCCI).
We will continue the discussions with CMS regarding new NCCI planned edits related to performing vaginal hysterectomy with enterocele repair when also performing colporrhapy.
ACOG will provide continuing updates on the process to resolve these problem edits.
ACOG would like to have records of all denied claims since October1, 2014 that have been re-filed with the new modifiers and are denied. As CMS has said they will pay those if adequately documented.