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2014 Financial Impact Analysis Doesn't Stop With CMS' Final Rule: Don't Neglect CMS NCCI Edits

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ASC facilities across the country are scrambling to determine the financial "winners" and "losers" for 2014.

Analysis of the CMS Final Rule should not be limited to the Medicare List of Approved ASC procedures and services for 2014 and each code's potential reimbursement, but also CMS' NCCI edit revisions in which clarifications may equal a loss in revenue.

As an example, the most notable revisions to CMS' NCCI edits 2014 can be found within Chapter IV Surgery Musculoskeletal System.

Per CMS:
•    4. "With the exception of the knee joint, arthroscopic debridement should not be reported separately with a surgical arthroscopy procedure when performed on the same joint at the same patient encounter…." CHAP4-CPTcodes 2000029999_final10312013.doc Revision Date: 1/1/2014 CHAPTER IV SURGERY: MUSCULOSKELETAL SYSTEM CPT CODES 20000- 29999

2014 NCCI edit code pairs should be reviewed and these revised guidelines considered.

Per CMS:
•    6. "Arthroscopic synovectomy of the knee may be reported with CPT codes 29875 (limited synovectomy, "separate procedure") or 29876 (major synovectomy of two or three compartments). A synovectomy to "clean up" a joint on which another more extensive procedure is performed is not separately reportable. CPT code 29875 should never be reported with another arthroscopic knee procedure on the ipsilateral knee. CPT code 29876 may be reported for a medically reasonable and necessary synovectomy with another arthroscopic knee procedure on the ipsilateral knee if the synovectomy is performed in two compartments on which another arthroscopic procedure is not performed. For example, CPT code 29876 should never be reported for a major synovectomy with CPT code 29880 (knee arthroscopy, medial AND lateral meniscectomy) on the ipsilateral knee since knee arthroscopic procedures other than synovectomy are performed in two of the three knee compartments." CHAP4-CPTcodes 2000029999_final10312013.doc Revision Date: 1/1/2014 CHAPTER IV SURGERY MUSCULOSKELETAL SYSTEM CPT CODES 20000- 29999

CMS directive #6 parallels with AMA responses to inquiries in 2013 as to the "separate procedure" definition and the reporting of CPT 29875 as directed above.

Your ASC coder is in the best position to determine whether his reporting practices will change each year. Meet with the coder and determine the financial impact of reporting practices that are modified.

Coding changes yearly, quarterly, monthly, daily. Continually research, review and retain AMA, CMS, specialty society, and carrier directives. More importantly, maintain a file to include month, date, year of your documentation in the event of an audit. Remember, dates of service audited should be based on directives for the timeframe in review.

Individual CMS NCCI Edits chapters can be retrieved on the CMS website at http://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/index.html. Simply Scroll down and click on NCCI Policy Manual for Medicare Services - Effective January 1, 2014 [ZIP, 749KB]

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