Facility Reimbursement for Multiple Procedures
More than one surgical procedure may be performed in the same operative session. Special rules apply to this situation. When two or more procedures are performed that are subject to the multiple procedure discount, the ASC will be reimbursed at the full rate for the procedure classified with the highest payment. Any other procedures performed during the same session are reimbursed at 50% of the procedure’s applicable payment.
A procedure performed bilaterally in one operative session is reported as two procedures. Report the CPT code as 2 line items, not 1 line item with 2 units. Payment for eligible bilateral procedures will be reimbursed at 150% of the applicable rate. Procedures eligible for the bilateral payment adjustment are determined by CMS.
The multiple procedure payment reduction is the last pricing routine applied to applicable ASC procedure codes. In determining the ranking of procedures for application of the multiple procedure reduction, NHIC shall use the lower of the billed charge or the ASC payment amount. The ASC surgical services billed with modifier -52 and -73 shall not be subjected to further pricing reductions. (i.e., the multiple procedure price reduction rules will not apply). Payment for an ASC surgical procedure billed with modifier -74 may be subject to the multiple procedure discount if that surgical procedure is subject to the multiple procedure discount.
Tuesday, June 29, 2010
Tips to improve ASC billing collection
Improving Your ASCs Billing and Collections
Five Important (And Sometimes Urgent) Areas to Address
These areas were chosen because of their ability to directly impact the center’s revenue stream, but are certainly not all of the areas that need to be assessed on a regular basis for continued financial success.
1. Fee Schedule
In most ASCs, the fee schedule is established when the center is opened and essentially ignored from that point forward. Occasionally the Board may decide to do a cost of living increase, but rarely is the fee schedule reviewed
• Do a spreadsheet and compare your fee schedule to reimbursement rates of your managed care contracts. Be sure the fees allow the necessary margin to maintain your budget.
• Assess your fee schedule in light of industry changes - changing Medicare reimbursement rates, increasing implant costs, competitive salary and benefit demands.
• Medicare group-based fee schedules should have carve-out fees for procedures that are time and supply intensive or require non-reimbursable implants.
Revising your fee schedule is fairly straightforward and often results in amazing
benefits. Review your fee schedule at least annually and update sooner if necessary.
2. Managed Care Contracts
Just complaining about low reimbursement rates will not fix the problem. The best way to improve reimbursement is to work with, not against, the managed care companies.
• Identify the representative that can make decisions about reimbursement rates and deal directly with them.
• Determine what areas you need to change, i.e.,
o Carve-out higher reimbursement rates for high ticket procedures
o Separate implant reimbursement
o Multiple procedure allowances and discounts
• Reciprocity is the name of the game - know where you can afford to offer reductions to compensate for what you want increased.
• Be able to support your requests for increased rates by providing case costs.
Most importantly, don’t just accept what they offer – negotiate!
3. Procedure Coding and Charge Entry
Employ certified and experienced surgical coders to optimize your reimbursement.
Investing a little more in payroll can often result in thousands of dollars in additional reimbursement while remaining compliant with OIG requirements.
• Remind your surgeons they can assist in revenue enhancement with detailed operative notes demonstrating medical necessity and complexity of procedure(s).
• Claim submission requires knowledge of procedure and diagnosis coding as well
as modifiers. In most centers coders perform charge entry and claim submission.
• Important reminders to keep your cash flow ongoing:
o Timeliness – claims need to be out the door within 48 hours following surgery
o Accuracy – recheck all areas of claim before submitting
o State-specific guidelines, i.e., modifiers, form variances, etc.
o Electronic submission wherever possible
Improving your revenue stream can often be as simple as setting specific goals for your
coding and billing staff and rewarding them for meeting or beating those goals.
4. Payment Posting and Denial Management
Getting paid is one thing - getting paid correctly is another! The more experienced the reimbursement specialist is relates directly to getting paid fully for services rendered.
• Your payment poster needs full access to current managed care contracts. This is key in determining accuracy of payments.
• Start denial process immediately for errors or non-payments.
• Develop a denial log to track reasons for denials. Track trends by payer, by surgeon, by coder, etc.
• If correctly paid, change responsibility for balance owed to secondary insurance or patient and bill immediately.
Denial management is one area where problems often go undetected. Inexperienced or interrupted payment posters often do not identify incorrect payments or a trend in denials. If denials are not followed up immediately, timely filing clauses in your contract may become a reason for the payer to contest liability for the amount due.
5. Accounts Receivable Management
Accounts receivable is an asset, meaning it’s money that is owed to the center that they anticipate collecting. When A/R is not managed properly it changes from an asset to bad debt. This is not a good thing! Again, experienced personnel are the key for good collections.
Contact the payer 15 days after submission of an electronic claim to determine
status of payment.
• Measure days your claim remains in accounts receivable - recommended 50 days or less.
• Measure percentage of claims still unpaid after 120 days - recommend less than 15%.
• Set achievable goals for your collector – how many accounts to touch per month? What percentage of collections in each area, 30 days, 60 days, etc.?
• Patient collections are often not worked because of time constraints. Evaluate the percentage of monies still owing at 120 days in patient accounts. A phone call to an overdue patient account often results in a credit card number or a promise of payment.
Because of the high percentage of managed care claims that are not paid on a timely basis or are paid incorrectly, collections are an important and sometimes daunting task. Don’t expect payments to arrive by themselves - this just doesn’t happen anymore - it takes constant effort to get the money you are owed.
Profitable centers don’t just happen; they are usually the product of hard work and well-thought-out financial planning. If you are a new center, following these commonsense
suggestions will assist you in meeting your financial goals. If your center is an existing center having financial difficulties, explore each of the areas referenced. Chances are you will find at least one area that can be improved.
Five Important (And Sometimes Urgent) Areas to Address
These areas were chosen because of their ability to directly impact the center’s revenue stream, but are certainly not all of the areas that need to be assessed on a regular basis for continued financial success.
1. Fee Schedule
In most ASCs, the fee schedule is established when the center is opened and essentially ignored from that point forward. Occasionally the Board may decide to do a cost of living increase, but rarely is the fee schedule reviewed
• Do a spreadsheet and compare your fee schedule to reimbursement rates of your managed care contracts. Be sure the fees allow the necessary margin to maintain your budget.
• Assess your fee schedule in light of industry changes - changing Medicare reimbursement rates, increasing implant costs, competitive salary and benefit demands.
• Medicare group-based fee schedules should have carve-out fees for procedures that are time and supply intensive or require non-reimbursable implants.
Revising your fee schedule is fairly straightforward and often results in amazing
benefits. Review your fee schedule at least annually and update sooner if necessary.
2. Managed Care Contracts
Just complaining about low reimbursement rates will not fix the problem. The best way to improve reimbursement is to work with, not against, the managed care companies.
• Identify the representative that can make decisions about reimbursement rates and deal directly with them.
• Determine what areas you need to change, i.e.,
o Carve-out higher reimbursement rates for high ticket procedures
o Separate implant reimbursement
o Multiple procedure allowances and discounts
• Reciprocity is the name of the game - know where you can afford to offer reductions to compensate for what you want increased.
• Be able to support your requests for increased rates by providing case costs.
Most importantly, don’t just accept what they offer – negotiate!
3. Procedure Coding and Charge Entry
Employ certified and experienced surgical coders to optimize your reimbursement.
Investing a little more in payroll can often result in thousands of dollars in additional reimbursement while remaining compliant with OIG requirements.
• Remind your surgeons they can assist in revenue enhancement with detailed operative notes demonstrating medical necessity and complexity of procedure(s).
• Claim submission requires knowledge of procedure and diagnosis coding as well
as modifiers. In most centers coders perform charge entry and claim submission.
• Important reminders to keep your cash flow ongoing:
o Timeliness – claims need to be out the door within 48 hours following surgery
o Accuracy – recheck all areas of claim before submitting
o State-specific guidelines, i.e., modifiers, form variances, etc.
o Electronic submission wherever possible
Improving your revenue stream can often be as simple as setting specific goals for your
coding and billing staff and rewarding them for meeting or beating those goals.
4. Payment Posting and Denial Management
Getting paid is one thing - getting paid correctly is another! The more experienced the reimbursement specialist is relates directly to getting paid fully for services rendered.
• Your payment poster needs full access to current managed care contracts. This is key in determining accuracy of payments.
• Start denial process immediately for errors or non-payments.
• Develop a denial log to track reasons for denials. Track trends by payer, by surgeon, by coder, etc.
• If correctly paid, change responsibility for balance owed to secondary insurance or patient and bill immediately.
Denial management is one area where problems often go undetected. Inexperienced or interrupted payment posters often do not identify incorrect payments or a trend in denials. If denials are not followed up immediately, timely filing clauses in your contract may become a reason for the payer to contest liability for the amount due.
5. Accounts Receivable Management
Accounts receivable is an asset, meaning it’s money that is owed to the center that they anticipate collecting. When A/R is not managed properly it changes from an asset to bad debt. This is not a good thing! Again, experienced personnel are the key for good collections.
Contact the payer 15 days after submission of an electronic claim to determine
status of payment.
• Measure days your claim remains in accounts receivable - recommended 50 days or less.
• Measure percentage of claims still unpaid after 120 days - recommend less than 15%.
• Set achievable goals for your collector – how many accounts to touch per month? What percentage of collections in each area, 30 days, 60 days, etc.?
• Patient collections are often not worked because of time constraints. Evaluate the percentage of monies still owing at 120 days in patient accounts. A phone call to an overdue patient account often results in a credit card number or a promise of payment.
Because of the high percentage of managed care claims that are not paid on a timely basis or are paid incorrectly, collections are an important and sometimes daunting task. Don’t expect payments to arrive by themselves - this just doesn’t happen anymore - it takes constant effort to get the money you are owed.
Profitable centers don’t just happen; they are usually the product of hard work and well-thought-out financial planning. If you are a new center, following these commonsense
suggestions will assist you in meeting your financial goals. If your center is an existing center having financial difficulties, explore each of the areas referenced. Chances are you will find at least one area that can be improved.
Billing and payment guide for ASC
MEDICARE REIMBURSEMENT FOR FLUOROSCOPIC GUIDANCE AND LOCALIZATION
DURING PAIN MANAGEMENT PROCEDURES
This advisory discusses Medicare coding, coverage and payment for mobile fluoroscopy
guidance during pain management procedures2, 3 when performed in the hospital inpatient,
hospital outpatient department, independent diagnostic testing facility (IDTF) and physician
office settings.4 While it focuses on Medicare program policies, these policies may also be
applicable to selected private payers throughout the country.
Coding
Medicare’s reimbursement system relies mostly on Current Procedural Terminology (CPT)
codes to consistently identify diagnostic imaging procedures provided to Medicare patients.5
The CPT coding system was developed and is maintained by the American Medical Association
(AMA) and the codes are updated annually. Updates for 2007 by the AMA include a significant
number of procedures being relocated to more appropriate sections within the CPT coding
structure. This relocation has resulted in the deletion and replacement of a considerable number
of CPT codes.6
Coding for Pain Management Procedures
There are a wide variety of pain management procedures. A listing of pain management
procedures and their related CPT codes is included in Table 1. This listing was developed based
on the following information sources: (1) procedures and codes identified by the American
Society of Interventional Pain Physicians, (2) additional codes listed in AMA coding
documentation as being included in the pain management coding series and (3) Healthcare
Common Procedure Coding System (HCPCS) codes developed by the Centers for Medicare and Medicaid Services (CMS) to report selected pain management procedures to the Medicare
program. It is important to note that inclusion of a procedure on this list does not denote
coverage or payment of the procedure.
Coding for Fluoroscopic Guidance and Localization
There are two CPT codes used to report fluoroscopic guidance and localization during pain
management injection procedures.
CPT 77002 Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization
device)
CPT 77003
Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous
diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid,
paravertebral facet joint, paravertebral facet joint nerve, or sacroiliac joint), including neurolytic
agent destruction
CPT code 77002 is used to report fluoroscopic guidance of all anatomical areas except the spine;
CPT code 77003 is used to report fluoroscopic guidance and localization of the spinal anatomy.
It is important to note that there are general limitations on the use of fluoroscopy codes. With
respect to coding of fluoroscopy procedures, the American College of Radiology (ACR) points
out “a general rule of thumb is if fluoroscopy is always performed as a part of the radiological
imaging study, fluoroscopy is included in the radiological procedure code.” In these cases,
fluoroscopy should not be coded or reported separately.7 Additionally, injection of contrast
during fluoroscopic guidance and localization is an inclusive component of pain management
codes and is not separately report.
There are more specific limitations with respect to the use of the codes listed above, as well as
limitations on reporting each of these codes separately with pain management injection
procedures. Table 2 summarizes guidance from the AMA and the ACR on when it is appropriate
to report fluoroscopy separately during pain management procedures. However, providers
should confirm that their local Medicare contractor has not published coding instructions
different than or inconsistent with this guidance before billing Medicare for fluoroscopy in
conjunction with pain management procedures.
DURING PAIN MANAGEMENT PROCEDURES
This advisory discusses Medicare coding, coverage and payment for mobile fluoroscopy
guidance during pain management procedures2, 3 when performed in the hospital inpatient,
hospital outpatient department, independent diagnostic testing facility (IDTF) and physician
office settings.4 While it focuses on Medicare program policies, these policies may also be
applicable to selected private payers throughout the country.
Coding
Medicare’s reimbursement system relies mostly on Current Procedural Terminology (CPT)
codes to consistently identify diagnostic imaging procedures provided to Medicare patients.5
The CPT coding system was developed and is maintained by the American Medical Association
(AMA) and the codes are updated annually. Updates for 2007 by the AMA include a significant
number of procedures being relocated to more appropriate sections within the CPT coding
structure. This relocation has resulted in the deletion and replacement of a considerable number
of CPT codes.6
Coding for Pain Management Procedures
There are a wide variety of pain management procedures. A listing of pain management
procedures and their related CPT codes is included in Table 1. This listing was developed based
on the following information sources: (1) procedures and codes identified by the American
Society of Interventional Pain Physicians, (2) additional codes listed in AMA coding
documentation as being included in the pain management coding series and (3) Healthcare
Common Procedure Coding System (HCPCS) codes developed by the Centers for Medicare and Medicaid Services (CMS) to report selected pain management procedures to the Medicare
program. It is important to note that inclusion of a procedure on this list does not denote
coverage or payment of the procedure.
Coding for Fluoroscopic Guidance and Localization
There are two CPT codes used to report fluoroscopic guidance and localization during pain
management injection procedures.
CPT 77002 Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization
device)
CPT 77003
Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous
diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid,
paravertebral facet joint, paravertebral facet joint nerve, or sacroiliac joint), including neurolytic
agent destruction
CPT code 77002 is used to report fluoroscopic guidance of all anatomical areas except the spine;
CPT code 77003 is used to report fluoroscopic guidance and localization of the spinal anatomy.
It is important to note that there are general limitations on the use of fluoroscopy codes. With
respect to coding of fluoroscopy procedures, the American College of Radiology (ACR) points
out “a general rule of thumb is if fluoroscopy is always performed as a part of the radiological
imaging study, fluoroscopy is included in the radiological procedure code.” In these cases,
fluoroscopy should not be coded or reported separately.7 Additionally, injection of contrast
during fluoroscopic guidance and localization is an inclusive component of pain management
codes and is not separately report.
There are more specific limitations with respect to the use of the codes listed above, as well as
limitations on reporting each of these codes separately with pain management injection
procedures. Table 2 summarizes guidance from the AMA and the ACR on when it is appropriate
to report fluoroscopy separately during pain management procedures. However, providers
should confirm that their local Medicare contractor has not published coding instructions
different than or inconsistent with this guidance before billing Medicare for fluoroscopy in
conjunction with pain management procedures.
Repoting fluoroscopy procedure codes
Other Requirements Associated with Reporting Fluoroscopy Procedure Codes
According to Medicare regulations, fluoroscopy procedures performed in physician offices,
IDTFs and, with certain exceptions, facilities designated by CMS as provider-based facilities
require personal supervision (i.e., a physician in attendance in the room during the performance
of the procedure).9 This requirement should typically be met because the fluoroscopy procedure
is performed in conjunction with a pain management procedure by a physician. Further, fluoroscopy procedures provided in hospital inpatient and outpatient settings should follow the
Joint Commission on Accreditation of Healthcare Organizations (JCAHO) accreditation
standards and internal hospital policies. Fluoroscopy services should not be coded or billed
unless these requirements are met.
Many of the pain management codes are subject to National Correct Coding Initiative (NCCI)
edits. NCCI edits are pairs of CPT or Healthcare Common Procedure Coding System (HCPCS)
codes that are not separately coded and payable except under certain circumstances. The edits
are applied to services billed by the same provider for the same beneficiary on the same date of
service and are updated on a quarterly basis. The NCCI edits may be obtained through the CMS
website at: http://www.cms.hhs.gov/NationalCorrectCodInitEd/.
When submitting claims to Medicare, procedural CPT codes are reported with diagnosis codes
describing the patient’s documented medical condition. These diagnoses are reported using the
International Classification of Diseases, Ninth Revision, Clinical Modification (ICD-9-CM).
According to Medicare regulations, fluoroscopy procedures performed in physician offices,
IDTFs and, with certain exceptions, facilities designated by CMS as provider-based facilities
require personal supervision (i.e., a physician in attendance in the room during the performance
of the procedure).9 This requirement should typically be met because the fluoroscopy procedure
is performed in conjunction with a pain management procedure by a physician. Further, fluoroscopy procedures provided in hospital inpatient and outpatient settings should follow the
Joint Commission on Accreditation of Healthcare Organizations (JCAHO) accreditation
standards and internal hospital policies. Fluoroscopy services should not be coded or billed
unless these requirements are met.
Many of the pain management codes are subject to National Correct Coding Initiative (NCCI)
edits. NCCI edits are pairs of CPT or Healthcare Common Procedure Coding System (HCPCS)
codes that are not separately coded and payable except under certain circumstances. The edits
are applied to services billed by the same provider for the same beneficiary on the same date of
service and are updated on a quarterly basis. The NCCI edits may be obtained through the CMS
website at: http://www.cms.hhs.gov/NationalCorrectCodInitEd/.
When submitting claims to Medicare, procedural CPT codes are reported with diagnosis codes
describing the patient’s documented medical condition. These diagnoses are reported using the
International Classification of Diseases, Ninth Revision, Clinical Modification (ICD-9-CM).
Coverage and Reimbursement for Fluoroscopy
Coverage and Reimbursement for Fluoroscopy
Coverage
Currently, Medicare does not have a national coverage policy that addresses fluoroscopy for pain
management procedures. Coverage of these procedures is at the discretion of local Medicare
contractors who process claims on behalf of the Medicare program. Providers should ascertain
coverage for the pain management procedure in addition to coverage for fluoroscopy itself.
Reimbursement
Medicare reimbursement for fluoroscopic guidance is comprised of a professional component,
the amount paid for the physician’s service, and a technical component, the amount paid for all
other services (including staffing and equipment costs). When these components are combined and paid to the same individual or entity, this is often referred to as the total or global
reimbursement.
Currently, Medicare reimburses fluoroscopic guidance differently depending on the site of care.
The technical component of the procedure performed in a physician’s office or IDTF is
reimbursed under the Medicare physician fee schedule. In a hospital outpatient department,
the technical component of a procedure is reimbursed under an Ambulatory Payment
Classification (APC) under Medicare’s hospital outpatient department prospective payment
system (HOPPS). In a hospital inpatient site of care, the technical (facility) payment is
subsumed within the payment to the hospital that is determined based on the Diagnosis Related
Group (DRG) to which the patient is assigned. The professional component is reimbursed under
the Medicare physician fee schedule regardless of setting.
In the case of a Medicare certified ambulatory surgical center (ASC), please note that the
technical component of fluoroscopy is not separately payable. However, when an ASC and
IDTF share space (but do not operate at the same time in that space), CMS and its local carriers
generally allow the IDTF to bill and be paid for by the program for the technical component of
fluoroscopy if it is reasonable and necessary, directly related to the performance of a surgical
procedure and furnished in conjunction with a surgical procedure during the ASC’s designated
hours.10 However, the ASC should consult with the local Medicare carriers regarding this issue
before submitting an IDTF enrollment application.
Table 3 provides information concerning Medicare national payment rates for fluoroscopy
imaging guidance performed in the hospital inpatient, hospital outpatient, IDTF and physician
office sites of service. It is important to note that, in the hospital outpatient site of care, the
fluoroscopy procedures are not reimbursed separately, but rather are “packaged” or included in
the APC payment to the hospital. For more information about reimbursement of these
procedures in your area, consult your local Medicare contractor.
Coverage
Currently, Medicare does not have a national coverage policy that addresses fluoroscopy for pain
management procedures. Coverage of these procedures is at the discretion of local Medicare
contractors who process claims on behalf of the Medicare program. Providers should ascertain
coverage for the pain management procedure in addition to coverage for fluoroscopy itself.
Reimbursement
Medicare reimbursement for fluoroscopic guidance is comprised of a professional component,
the amount paid for the physician’s service, and a technical component, the amount paid for all
other services (including staffing and equipment costs). When these components are combined and paid to the same individual or entity, this is often referred to as the total or global
reimbursement.
Currently, Medicare reimburses fluoroscopic guidance differently depending on the site of care.
The technical component of the procedure performed in a physician’s office or IDTF is
reimbursed under the Medicare physician fee schedule. In a hospital outpatient department,
the technical component of a procedure is reimbursed under an Ambulatory Payment
Classification (APC) under Medicare’s hospital outpatient department prospective payment
system (HOPPS). In a hospital inpatient site of care, the technical (facility) payment is
subsumed within the payment to the hospital that is determined based on the Diagnosis Related
Group (DRG) to which the patient is assigned. The professional component is reimbursed under
the Medicare physician fee schedule regardless of setting.
In the case of a Medicare certified ambulatory surgical center (ASC), please note that the
technical component of fluoroscopy is not separately payable. However, when an ASC and
IDTF share space (but do not operate at the same time in that space), CMS and its local carriers
generally allow the IDTF to bill and be paid for by the program for the technical component of
fluoroscopy if it is reasonable and necessary, directly related to the performance of a surgical
procedure and furnished in conjunction with a surgical procedure during the ASC’s designated
hours.10 However, the ASC should consult with the local Medicare carriers regarding this issue
before submitting an IDTF enrollment application.
Table 3 provides information concerning Medicare national payment rates for fluoroscopy
imaging guidance performed in the hospital inpatient, hospital outpatient, IDTF and physician
office sites of service. It is important to note that, in the hospital outpatient site of care, the
fluoroscopy procedures are not reimbursed separately, but rather are “packaged” or included in
the APC payment to the hospital. For more information about reimbursement of these
procedures in your area, consult your local Medicare contractor.
Pain Management cpt / HCPCS codes
Table 1: Pain Management Procedures
CPT/HCPCS Code Description
20526 Injection, therapeutic (eg, local anesthetic, corticosteroid), carpal tunnel
20550 Injection(s); single tendon sheath, or ligament, aponeurosis (eg, plantar “fascia”)
20551 Injection(s); single tendon origin/insertion
20552 Injection(s); single or multiple trigger point(s), one or two muscle(s)
20553 Injection(s); single or multiple trigger point(s), three or more muscle(s)
20600 Arthrocentesis, aspiration and/or injection; small joint or bursa (eg, fingers, toes)
20605 Arthrocentesis, aspiration and/or injection; intermediate joint or bursa (eg,
temporomandibular, acromioclavicular, wrist, elbow or ankle, olecranon bursa)
20610 Arthrocentesis, aspiration and/or injection; major joint or bursa (eg, shoulder, hip, knee joint, subacromial bursa)
27093 Injection procedure for hip arthrography; without anesthesia
27096 Injection procedure for sacroiliac joint, arthrography and/or anesthetic/steroid
62263 Percutaneous lysis of epidural adhesions using solution injection (eg, hypertonic saline,
enzyme) or mechanical means (eg, catheter) including radiologic localization (includes
contrast when administered), multiple adhesiolysis sessions; 2 or more days
62264 Percutaneous lysis of epidural adhesions using solution injection (eg, hypertonic saline,
enzyme) or mechanical means (eg, catheter) including radiologic localization (includes
contrast when administered), multiple adhesiolysis sessions; 1 day
62268 Percutaneous aspiration, spinal cord cyst or syrinx
62269 Biopsy of spinal cord, percutaneous needle
62270 Spinal puncture, lumbar, diagnostic
62272 Spinal puncture, therapeutic, for drainage of cerebrospinal fluid (by needle or catheter)
62273 Injection, epidural, of blood or clot patch
62280 Injection/infusion of neurolytic substance (eg, alcohol, phenol, iced saline solutions), with or without other therapeutic substance; subarachnoid
62281 Injection/infusion of neurolytic substance (eg, alcohol, phenol, iced saline solutions), with or without other therapeutic substance; epidural, cervical or thoracic
62282 Injection/infusion of neurolytic substance (eg, alcohol, phenol, iced saline solutions), with or without other therapeutic substance; epidural, lumbar, sacral (caudal)
62284 Injection procedure for myelography and/or computed tomography, spinal (other than C1-C2
and posterior fossa)
62287 Aspiration or decompression procedure, percutaneous, of nucleus pulposus of intervertebral disc, any method, single or multiple levels, lumbar (eg, manual or automated percutaneous discectomy, percutaneous laser discectomy)
62290 Injection procedure for discography, each level; lumbar
62291 Injection procedure for discography, each level; cervical or thoracic
62292 Injection procedure for chemonucleolysis, including discography, intervertebral disc, single
or multiple levels, lumbar
62310 Injection, single (not via indwelling catheter), not including neurolytic substances, with or
without contrast (for either localization or epidurography), of diagnostic or therapeutic
substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), epidural or
subarachnoid; cervical or thoracic
62311 Injection, single (not via indwelling catheter), not including neurolytic substances, with or
without contrast (for either localization or epidurography), of diagnostic or therapeutic
substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), epidural or
subarachnoid; lumbar, sacral (caudal)
62318 Injection, including catheter placement, continuous infusion or intermittent bolus, not
including neurolytic substances, with or without contrast (for either localization or
epidurography), of diagnostic or therapeutic substance(s) (including anesthetic,
antispasmodic, opioid, steroid, other solution), epidural or subarachnoid; cervical or thoracic
62319 Injection, including catheter placement, continuous infusion or intermittent bolus, not including neurolytic substances, with or without contrast (for either localization or epidurography), of diagnostic or therapeutic substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), epidural or subarachnoid; lumbar, sacral (caudal)
62350 Implantation, revision or repositioning of tunneled intrathecal or epidural catheter, for longterm medication administration via an external pump or implantable reservoir/infusion pump;
without laminectomy
62355 Removal of previously implanted intrathecal or epidural catheter
62360 Implantation or replacement of device for intrathecal or epidural drug infusion; ubcutaneous
reservoir
62361 Implantation or replacement of device for intrathecal or epidural drug infusion; nonprogrammable pump
62362 Implantation or replacement of device for intrathecal or epidural drug infusion;
programmable pump, including preparation of pump, with or without programming
62365 Removal of subcutaneous reservoir or pump, previously implanted for intrathecal or epidural
infusion
62367 Electronic analysis of programmable, implanted pump for intrathecal or epidural drug
infusion (includes evaluation of reservoir status, alarm status, drug prescription status);
without reprogramming
62368 Electronic analysis of programmable, implanted pump for intrathecal or epidural drug
infusion (includes evaluation of reservoir status, alarm status, drug prescription status); with
reprogramming
63650 Percutaneous implantation of neurostimulator electrode array, epidural
63660 Revision or removal of spinal neurostimulator electrode percutaneous array(s) or
plate/paddle(s)
63685 Insertion or replacement of spinal neurostimulator pulse generator or receiver, direct or
inductive coupling
63688 Revision or removal of implanted spinal neurostimulator pulse generator or receiver
64400 Injection, anesthetic agent; trigeminal nerve, any division or branch
64402 Injection, anesthetic agent; facial nerve
64405 Injection, anesthetic agent; greater occipital nerve
64408 Injection, anesthetic agent; vagus nerve
64410 Injection, anesthetic agent; phrenic nerve
64412 Injection, anesthetic agent; spinal accessory nerve
64413 Injection, anesthetic agent; cervical plexus
64415 Injection, anesthetic agent; brachial plexus, single
64416 Injection, anesthetic agent; brachial plexus, continuous infusion by catheter (including
catheter placement) including daily management for anesthetic agent administration
64417 Injection, anesthetic agent; axillary nerve
64418 Injection, anesthetic agent; suprascapular nerve
64420 Injection, anesthetic agent; intercostal nerve, single
64421 Injection, anesthetic agent; intercostal nerves, multiple, regional block
64425 Injection, anesthetic agent; ilioinguinal, iliohypogastric nerves
64430 Injection, anesthetic agent; pudendal nerve
64435 Injection, anesthetic agent; paracervical (uterine) nerve
64445 Injection, anesthetic agent; sciatic nerve, single
64446 Injection, anesthetic agent; sciatic nerve, continuous infusion by catheter, (including catheter placement) including daily management for anesthetic agent administration
64447 Injection, anesthetic agent; femoral nerve, single
64448 Injection, anesthetic agent; femoral nerve, continuous infusion by catheter (including catheter placement) including daily management for anesthetic agent administration
64449 Injection, anesthetic agent; lumbar plexus, posterior approach, continuous infusion by
catheter (including catheter placement) including daily management for anesthetic agent
administration
64450 Injection, anesthetic agent; other peripheral nerve or branch
64470 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve;
cervical or thoracic, single level
64472 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve;
cervical or thoracic, each additional level (List separately in addition to code for primary
procedure)
64475 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve; lumbar or sacral, single level
64476 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve; lumbar or sacral, each additional level (List separately in addition to code for primary procedure)
64479 Injection, anesthetic agent and/or steroid, transforaminal epidural; cervical or thoracic, single level
64480 Injection, anesthetic agent and/or steroid, transforaminal epidural; cervical or thoracic, each
additional level (List separately in addition to code for primary procedure)
64483 Injection, anesthetic agent and/or steroid, transforaminal epidural; lumbar or sacral, single
level
64484 Injection, anesthetic agent and/or steroid, transforaminal epidural; lumbar or sacral, each
additional level (List separately in addition to code for primary procedure)
64505 Injection, anesthetic agent; sphenopalatine ganglion
64508 Injection, anesthetic agent; carotid sinus (separate procedure)
64510 Injection, anesthetic agent; stellate ganglion (cervical sympathetic)
64517 Injection, anesthetic agent; superior hypogastric plexus
64520 Injection, anesthetic agent; lumbar or thoracic (paravertebral sympathetic)
64530 Injection, anesthetic agent; celiac plexus, with or without radiologic monitoring
64600 Destruction by neurolytic agent, trigeminal nerve; supraorbital, infraorbital, mental, or
inferior alveolar branch
64605 Destruction by neurolytic agent, trigeminal nerve; second and third division branches at
foramen ovale
64610 Destruction by neurolytic agent, trigeminal nerve; second and third division branches at
foramen ovale under radiologic monitoring
64612 Chemodenervation of muscle(s); muscle(s) innervated by facial nerve (eg, for blepharospasm,
hemifacial spasm)
64613 Chemodenervation of muscle(s); neck muscle(s) (eg, for spasmodic torticollis, spasmodic
dysphonia)
64614 Chemodenervation of muscle(s); extremity(s) and/or trunk muscle(s) (eg, for dystonia,
cerebral palsy, multiple sclerosis)
64620 Destruction by neurolytic agent, intercostal nerve
64622 Destruction by neurolytic agent, paravertebral facet joint nerve; lumbar or sacral, single level
64623 Destruction by neurolytic agent, paravertebral facet joint nerve; lumbar or sacral, each
additional level (List separately in addition to code for primary procedure)
64626 Destruction by neurolytic agent, paravertebral facet joint nerve; cervical or thoracic, single
level
64627 Destruction by neurolytic agent, paravertebral facet joint nerve; cervical or thoracic, each
additional level (List separately in addition to code for primary procedure)
64630 Destruction by neurolytic agent; pudendal nerve
64640 Destruction by neurolytic agent; other peripheral nerve or branch
64680 Destruction by neurolytic agent, with or without radiologic monitoring; celiac plexus
64681 Destruction by neurolytic agent, with or without radiologic monitoring; superior hypogastric
plexus
77002 Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization
device)
77003 Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous
diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid, paravertebral facet joint, paravertebral facet joint nerve or sacroiliac joint), including neurolytic agent destruction
G0259 Injection procedure for sacroiliac joint; arthrography
G0260 Injection procedure for sacroiliac joint; provision of anesthetic, steroid and/or other
therapeutic agent, with or without arthrography
CPT/HCPCS Code Description
20526 Injection, therapeutic (eg, local anesthetic, corticosteroid), carpal tunnel
20550 Injection(s); single tendon sheath, or ligament, aponeurosis (eg, plantar “fascia”)
20551 Injection(s); single tendon origin/insertion
20552 Injection(s); single or multiple trigger point(s), one or two muscle(s)
20553 Injection(s); single or multiple trigger point(s), three or more muscle(s)
20600 Arthrocentesis, aspiration and/or injection; small joint or bursa (eg, fingers, toes)
20605 Arthrocentesis, aspiration and/or injection; intermediate joint or bursa (eg,
temporomandibular, acromioclavicular, wrist, elbow or ankle, olecranon bursa)
20610 Arthrocentesis, aspiration and/or injection; major joint or bursa (eg, shoulder, hip, knee joint, subacromial bursa)
27093 Injection procedure for hip arthrography; without anesthesia
27096 Injection procedure for sacroiliac joint, arthrography and/or anesthetic/steroid
62263 Percutaneous lysis of epidural adhesions using solution injection (eg, hypertonic saline,
enzyme) or mechanical means (eg, catheter) including radiologic localization (includes
contrast when administered), multiple adhesiolysis sessions; 2 or more days
62264 Percutaneous lysis of epidural adhesions using solution injection (eg, hypertonic saline,
enzyme) or mechanical means (eg, catheter) including radiologic localization (includes
contrast when administered), multiple adhesiolysis sessions; 1 day
62268 Percutaneous aspiration, spinal cord cyst or syrinx
62269 Biopsy of spinal cord, percutaneous needle
62270 Spinal puncture, lumbar, diagnostic
62272 Spinal puncture, therapeutic, for drainage of cerebrospinal fluid (by needle or catheter)
62273 Injection, epidural, of blood or clot patch
62280 Injection/infusion of neurolytic substance (eg, alcohol, phenol, iced saline solutions), with or without other therapeutic substance; subarachnoid
62281 Injection/infusion of neurolytic substance (eg, alcohol, phenol, iced saline solutions), with or without other therapeutic substance; epidural, cervical or thoracic
62282 Injection/infusion of neurolytic substance (eg, alcohol, phenol, iced saline solutions), with or without other therapeutic substance; epidural, lumbar, sacral (caudal)
62284 Injection procedure for myelography and/or computed tomography, spinal (other than C1-C2
and posterior fossa)
62287 Aspiration or decompression procedure, percutaneous, of nucleus pulposus of intervertebral disc, any method, single or multiple levels, lumbar (eg, manual or automated percutaneous discectomy, percutaneous laser discectomy)
62290 Injection procedure for discography, each level; lumbar
62291 Injection procedure for discography, each level; cervical or thoracic
62292 Injection procedure for chemonucleolysis, including discography, intervertebral disc, single
or multiple levels, lumbar
62310 Injection, single (not via indwelling catheter), not including neurolytic substances, with or
without contrast (for either localization or epidurography), of diagnostic or therapeutic
substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), epidural or
subarachnoid; cervical or thoracic
62311 Injection, single (not via indwelling catheter), not including neurolytic substances, with or
without contrast (for either localization or epidurography), of diagnostic or therapeutic
substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), epidural or
subarachnoid; lumbar, sacral (caudal)
62318 Injection, including catheter placement, continuous infusion or intermittent bolus, not
including neurolytic substances, with or without contrast (for either localization or
epidurography), of diagnostic or therapeutic substance(s) (including anesthetic,
antispasmodic, opioid, steroid, other solution), epidural or subarachnoid; cervical or thoracic
62319 Injection, including catheter placement, continuous infusion or intermittent bolus, not including neurolytic substances, with or without contrast (for either localization or epidurography), of diagnostic or therapeutic substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), epidural or subarachnoid; lumbar, sacral (caudal)
62350 Implantation, revision or repositioning of tunneled intrathecal or epidural catheter, for longterm medication administration via an external pump or implantable reservoir/infusion pump;
without laminectomy
62355 Removal of previously implanted intrathecal or epidural catheter
62360 Implantation or replacement of device for intrathecal or epidural drug infusion; ubcutaneous
reservoir
62361 Implantation or replacement of device for intrathecal or epidural drug infusion; nonprogrammable pump
62362 Implantation or replacement of device for intrathecal or epidural drug infusion;
programmable pump, including preparation of pump, with or without programming
62365 Removal of subcutaneous reservoir or pump, previously implanted for intrathecal or epidural
infusion
62367 Electronic analysis of programmable, implanted pump for intrathecal or epidural drug
infusion (includes evaluation of reservoir status, alarm status, drug prescription status);
without reprogramming
62368 Electronic analysis of programmable, implanted pump for intrathecal or epidural drug
infusion (includes evaluation of reservoir status, alarm status, drug prescription status); with
reprogramming
63650 Percutaneous implantation of neurostimulator electrode array, epidural
63660 Revision or removal of spinal neurostimulator electrode percutaneous array(s) or
plate/paddle(s)
63685 Insertion or replacement of spinal neurostimulator pulse generator or receiver, direct or
inductive coupling
63688 Revision or removal of implanted spinal neurostimulator pulse generator or receiver
64400 Injection, anesthetic agent; trigeminal nerve, any division or branch
64402 Injection, anesthetic agent; facial nerve
64405 Injection, anesthetic agent; greater occipital nerve
64408 Injection, anesthetic agent; vagus nerve
64410 Injection, anesthetic agent; phrenic nerve
64412 Injection, anesthetic agent; spinal accessory nerve
64413 Injection, anesthetic agent; cervical plexus
64415 Injection, anesthetic agent; brachial plexus, single
64416 Injection, anesthetic agent; brachial plexus, continuous infusion by catheter (including
catheter placement) including daily management for anesthetic agent administration
64417 Injection, anesthetic agent; axillary nerve
64418 Injection, anesthetic agent; suprascapular nerve
64420 Injection, anesthetic agent; intercostal nerve, single
64421 Injection, anesthetic agent; intercostal nerves, multiple, regional block
64425 Injection, anesthetic agent; ilioinguinal, iliohypogastric nerves
64430 Injection, anesthetic agent; pudendal nerve
64435 Injection, anesthetic agent; paracervical (uterine) nerve
64445 Injection, anesthetic agent; sciatic nerve, single
64446 Injection, anesthetic agent; sciatic nerve, continuous infusion by catheter, (including catheter placement) including daily management for anesthetic agent administration
64447 Injection, anesthetic agent; femoral nerve, single
64448 Injection, anesthetic agent; femoral nerve, continuous infusion by catheter (including catheter placement) including daily management for anesthetic agent administration
64449 Injection, anesthetic agent; lumbar plexus, posterior approach, continuous infusion by
catheter (including catheter placement) including daily management for anesthetic agent
administration
64450 Injection, anesthetic agent; other peripheral nerve or branch
64470 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve;
cervical or thoracic, single level
64472 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve;
cervical or thoracic, each additional level (List separately in addition to code for primary
procedure)
64475 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve; lumbar or sacral, single level
64476 Injection, anesthetic agent and/or steroid, paravertebral facet joint or facet joint nerve; lumbar or sacral, each additional level (List separately in addition to code for primary procedure)
64479 Injection, anesthetic agent and/or steroid, transforaminal epidural; cervical or thoracic, single level
64480 Injection, anesthetic agent and/or steroid, transforaminal epidural; cervical or thoracic, each
additional level (List separately in addition to code for primary procedure)
64483 Injection, anesthetic agent and/or steroid, transforaminal epidural; lumbar or sacral, single
level
64484 Injection, anesthetic agent and/or steroid, transforaminal epidural; lumbar or sacral, each
additional level (List separately in addition to code for primary procedure)
64505 Injection, anesthetic agent; sphenopalatine ganglion
64508 Injection, anesthetic agent; carotid sinus (separate procedure)
64510 Injection, anesthetic agent; stellate ganglion (cervical sympathetic)
64517 Injection, anesthetic agent; superior hypogastric plexus
64520 Injection, anesthetic agent; lumbar or thoracic (paravertebral sympathetic)
64530 Injection, anesthetic agent; celiac plexus, with or without radiologic monitoring
64600 Destruction by neurolytic agent, trigeminal nerve; supraorbital, infraorbital, mental, or
inferior alveolar branch
64605 Destruction by neurolytic agent, trigeminal nerve; second and third division branches at
foramen ovale
64610 Destruction by neurolytic agent, trigeminal nerve; second and third division branches at
foramen ovale under radiologic monitoring
64612 Chemodenervation of muscle(s); muscle(s) innervated by facial nerve (eg, for blepharospasm,
hemifacial spasm)
64613 Chemodenervation of muscle(s); neck muscle(s) (eg, for spasmodic torticollis, spasmodic
dysphonia)
64614 Chemodenervation of muscle(s); extremity(s) and/or trunk muscle(s) (eg, for dystonia,
cerebral palsy, multiple sclerosis)
64620 Destruction by neurolytic agent, intercostal nerve
64622 Destruction by neurolytic agent, paravertebral facet joint nerve; lumbar or sacral, single level
64623 Destruction by neurolytic agent, paravertebral facet joint nerve; lumbar or sacral, each
additional level (List separately in addition to code for primary procedure)
64626 Destruction by neurolytic agent, paravertebral facet joint nerve; cervical or thoracic, single
level
64627 Destruction by neurolytic agent, paravertebral facet joint nerve; cervical or thoracic, each
additional level (List separately in addition to code for primary procedure)
64630 Destruction by neurolytic agent; pudendal nerve
64640 Destruction by neurolytic agent; other peripheral nerve or branch
64680 Destruction by neurolytic agent, with or without radiologic monitoring; celiac plexus
64681 Destruction by neurolytic agent, with or without radiologic monitoring; superior hypogastric
plexus
77002 Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization
device)
77003 Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous
diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid, paravertebral facet joint, paravertebral facet joint nerve or sacroiliac joint), including neurolytic agent destruction
G0259 Injection procedure for sacroiliac joint; arthrography
G0260 Injection procedure for sacroiliac joint; provision of anesthetic, steroid and/or other
therapeutic agent, with or without arthrography
CPT - 76003 , 70332 & 77003 - Fluoroscopic Guidance in Pain Management Procedures
Table 2: Coding for Fluoroscopic Guidance in Pain Management Procedures
CPT CODE and description
77002 - Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization device) average fee amount - $90 - $100
77003 - Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural or subarachnoid) average fee amount - $80 - $100
76003 Fluoroscopic guidance for needle placement (e.g., biopsy, aspiration, injection, localization device)
In 2010, there were major changes to the Facet Injection codes, and the Medicare ASC List fee schedule is reimbursing significantly less for these procedures. These codes include the use of imaging, so the 77003 Fluoroscopy or other imaging technique codes are not billed separately with the new codes. These codes have a different code for each level billed. The last code allowable for each spinal area (i.e., Cervical, Lumbar, etc.) is for the 3rd level and the code states that it “cannot be billed more than once per day,”
Billing and Coding Guidelines
An imaging guidance code is billed only once per session for CPT code 77003, fluoroscopy or CPT code 77012 for CT guidance. Physicians may only bill for the professional component when imaging is performed in a hospital or non-office facility. No claim should be submitted for the hard or digital film(s) maintained to document needle placement.
The CPT code 72275 (Epidurography, radiological supervision and interpretation) differs from CPT code 77003 in that it represents a formal recorded and reported contrast study that includes fluoroscopy. Epidurography should only be reported when it is reasonable and medically necessary to perform a diagnostic study. Epidurography should not be billed when the contrast injection is part of the fluoroscopic guidance and contrast injection to confirm correct needle placement that is integral to the epidural, transforaminal and intrathecal injections addressed in the policy.
For example, CPT code 70332 describes radiological supervision and interpretation of a temporomandibular joint arthrogram. The CPT Manual instruction following CPT code 70332 states: “(Do not report 70332 in conjunction with 77002).” Therefore, CPT code 77002 (Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization device)) is bundled into CPT code 70332.
Misuse of column two code with column one code - For example, CPT code 76930 describes imaging supervision and interpretation for ultrasound guidance for pericardiocentesis. CPT code 77002 describes fluoroscopic guidance for needle placement. Since imaging supervision and interpretation codes include all radiological services necessary to complete the service, it is a misuse of CPT code 77002 to report it separately with CPT code 76930. Therefore, CPT code 77002 is bundled into CPT code 76930.
1. The HCPCS/CPT code(s) may be subject to Correct Coding initiative (CCI) edits. This policy does not take precedence over CCI edits. Please refer to the current version CCI for correct coding guidelines and specific applicable code combinations prior to billing Medicare.
2. All procedures related to pain management procedures performed by the physician/provider performed on the same day must be billed on the same claim.
3. An imaging guidance code is billed only once per session for CPT code 77003, fluoroscopy or CPT code 77012 for CT guidance. Physicians may only bill for the professional component when imaging is performed in a hospital or non-office facility. No claim should be submitted for the hard or digital film(s) maintained to document needle placement.
4. The CPT code 72275 (Epidurography, radiological supervision and interpretation) differs from CPT code 77003 in that it represents a formal recorded and reported contrast study that includes fluoroscopy. Epidurography should only be reported when it is reasonable and medically necessary to perform a diagnostic study. Epidurography should not be billed when the contrast injection is part of the fluoroscopic guidance and contrast injection to confirm correct needle placement that is integral to the epidural, transforaminal and intrathecal injections addressed in the policy.
ADVISORY PANEL ON AMBULATORY PAYMENT CLASSIFICATION (APC) GROUPS
The Panel recommends that CMS maintain the packaged status of the following:
• CPT code 76001, Fluoroscopy, physician time more than one hour, assisting a nonradiologic physician (e.g., nephrostolithotomy, ERCP, bronchoscopy, transbronchial biopsy)
• CPT code 76003, Fluoroscopic guidance for needle placement (e.g., biopsy, aspiration, injection, localization device)
• CPT code 76005, Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid, paravertebral facet joint, paravertebral facet joint nerve or sacroiliac joint), including neurolytic agent destruction.
Anthem Central Region Clinical Claims
Subject: Fluoroscopic Guidance for Needle Placement (e.g., Biopsy, Aspiration, Injection, Localization Device) with Magnetic Resonance (e.g., Proton) any Joint of Upper Extremity; with Contrast Material(s) or with Injection Procedure for Shoulder Arthrography or Enhanced CT/MRI Shoulder Arthrography.
76003 (Fluoroscopic guidance for needle placement{e.g., biopsy, aspiration, injection, localization device}) does not bundle with 73222 (Magnetic resonance [e.g., proton}, any joint of upper extremity; with contrast material(s).
76003-26 (Fluoroscopic guidance for needle placement{e.g., biopsy, aspiration, injection, localization device}) does not bundle with 73222-26 (Magnetic resonance [e.g., proton}, any joint of upper extremity; with contrast material(s).
76003-TC (Fluoroscopic guidance for needle placement{e.g., biopsy, aspiration, injection, localization device}) does not bundle with 73222-TC (Magnetic resonance [e.g., proton}, any joint of upper extremity; with contrast material(s).
76003 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350 (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
76003-26 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350-50 (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
76003-26 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350-LT (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
76003 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350-RT (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
Anthem Central Region does not bundle 76003 with 73222, does not bundle 76003-26 with 73222-26, and does not bundle 76003-TC with 73222-TC. Based on CPT article, Coding Clarification, Radiology Procedures, it states:
“It is important to note that MRI obtained after intraarticular administration of contrast (MR arthrography) should be coded as a "with contrast examination." In addition, it is appropriate to report the appropriate procedure code and guidance code (if used) for injection of contrast into the joint. For instance, to report an MRI of the shoulder with intra-articular contrast (MR arthrography of the shoulder), it is appropriate to report 23350 for the shoulder joint injection. You would report 76003 if fluoroscopic guidance was used to guide needle placement into the joint, and 73222 for the MRI shoulder with contrast.”
Based on the National Correct Coding Initiative Edits, code 76003 is not listed as a component code to code 73222. Therefore, if 76003 is submitted with 73222—both reimburse separately, if 76003-26 is submitted with 73222-26—both reimburse separately, if 76003-LT is submitted with 73222-LT—both reimburse separately, if 76003-RT is submitted with 73222-RT—both reimburse separately and if 76003- TC is submitted with 73222-TC—both reimburse separately.
Anthem Central Region does not bundle 76003 with 23350, does not bundle 76003-26 with 23350-50, does not bundle 76003-26 with 23350-LT and does not bundle 76003-26 with 23350-RT. Based on the National Correct Coding Initiative Edits, code 76003 is not listed as a component code to code 23350. Therefore, if 76003 is submitted with 23350—both reimburse separately, if 76003-26 is submitted with 23350-50 .
Whether there should be reimbursement for CPT codes 27299-51, 22899-51, 38230, 95920, 95937 and 76003 for date of service 03-05-04.
RATIONALE
CPT code 27299-51 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). The carrier’s position states that code 27299-51 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg. IX#9. Per Ingenix EncoderPro CPT code 27299-51 is not a global procedure code. Per Rule 133.1(a)(8) fair and reasonable reimbursement – the carrier did not state an amount. Reimbursement is recommended per the Medical Fee Schedule effective 08-01-03 in the amount of $1400.00.
CPT code 22899-51 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). The carrier’s position states that code 22899-51 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg. IX#9. Per Ingenix EncoderPro CPT code 22899-51 is not a global procedure code. Per Rule 133.1(a)(8) fair and reasonable reimbursement – the carrier did not state an amount. Reimbursement is recommended per the Medical Fee Schedule effective 08-01-03 in the amount of $1200.00.
CPT code 38230 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). The carrier’s position states that code 38230 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg. X. Per Ingenix EncoderPro CPT code 38230 is not a global procedure code. The MAR per the Medical Fee
MDR Tracking #: M5-05-0126 01 Schedule effective 08-01-03 is $366.39 ($293.11 X 125%), however the requestor billed $183.19, therefore this is the recommended amount of reimbursement.
CPT codes 95920 and 95937 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). Per Ingenix EncoderPro CCI edits CPT codes 95920 and 95937 are global to CPT code 22612 which was the primary procedure billed per the EOB. No reimbursement is recommended. CPT code 76003 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement).
The carrier’s position states that code 76003 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg.viii#6. Per Ingenix EncoderPro CPT code 76003 is not a global procedure code. Reimbursement per the Medical Fee Guideline effective 08-01-03 in the amount of $98.08 ($78.46 X 125%) is recommended.
IV. DECISION
Based upon the review of the disputed healthcare services within this request, the Division has determined that the requestor is entitled to reimbursement for CPT codes 27299-51, 22899-51, 38230 and 76003. The Division has determined that the requestor is not entitled to reimbursement for CPT codes 95920 and 95937.
| CPT Code and Description | When Not to Report the Code Separately | When to Report the code Separately | Other |
| All anatomical areas except the spine 77002 Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization device) | CPT code 76003 should not be reported separately with any radiographic arthrography (CPT 70332, 73040, 73085, 73115, 73525, 73580, 73615) with the exception of supervision and interpretation for CT and MR arthrography. | Report this code when fluoroscopic guidance is required in the performance of needle placement in areas other than spine, for pain management injection procedures. CPT code 77002 should be reported in conjunction with the primary pain management procedure. | Injection of contrast during fluoroscopic guidance is an inclusive component and is not separately reported. |
| Spine 77003 Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid, paravertebral facet joint, paravertebral facet joint nerve or sacroiliac joint), including neurolytic agent destruction. | CPT code 77003 should not be reported separately with myelography, epidurography, arthrography, or discography. | Report this code when fluoroscopic guidance is required in the performance of spinal or paraspinous injection procedures, as long as these procedures are not myelography, epidurography, arthrography or discography. CPT code 76005 should be reported in conjunction with injection codes (CPT 62270-62273, 62280- 62282, 62310-62319, 64470-64476, 64479- 64484 and 64622-64627; and in certain circumstances with CPT 27096). | Injection of contrast during fluoroscopic guidance and localization is an inclusive component and is not separately reported. Reported per spinal region (e.g., cervical, lumbar), and not per level. |
77002 - Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization device) average fee amount - $90 - $100
77003 - Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural or subarachnoid) average fee amount - $80 - $100
76003 Fluoroscopic guidance for needle placement (e.g., biopsy, aspiration, injection, localization device)
In 2010, there were major changes to the Facet Injection codes, and the Medicare ASC List fee schedule is reimbursing significantly less for these procedures. These codes include the use of imaging, so the 77003 Fluoroscopy or other imaging technique codes are not billed separately with the new codes. These codes have a different code for each level billed. The last code allowable for each spinal area (i.e., Cervical, Lumbar, etc.) is for the 3rd level and the code states that it “cannot be billed more than once per day,”
Billing and Coding Guidelines
An imaging guidance code is billed only once per session for CPT code 77003, fluoroscopy or CPT code 77012 for CT guidance. Physicians may only bill for the professional component when imaging is performed in a hospital or non-office facility. No claim should be submitted for the hard or digital film(s) maintained to document needle placement.
The CPT code 72275 (Epidurography, radiological supervision and interpretation) differs from CPT code 77003 in that it represents a formal recorded and reported contrast study that includes fluoroscopy. Epidurography should only be reported when it is reasonable and medically necessary to perform a diagnostic study. Epidurography should not be billed when the contrast injection is part of the fluoroscopic guidance and contrast injection to confirm correct needle placement that is integral to the epidural, transforaminal and intrathecal injections addressed in the policy.
For example, CPT code 70332 describes radiological supervision and interpretation of a temporomandibular joint arthrogram. The CPT Manual instruction following CPT code 70332 states: “(Do not report 70332 in conjunction with 77002).” Therefore, CPT code 77002 (Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization device)) is bundled into CPT code 70332.
Misuse of column two code with column one code - For example, CPT code 76930 describes imaging supervision and interpretation for ultrasound guidance for pericardiocentesis. CPT code 77002 describes fluoroscopic guidance for needle placement. Since imaging supervision and interpretation codes include all radiological services necessary to complete the service, it is a misuse of CPT code 77002 to report it separately with CPT code 76930. Therefore, CPT code 77002 is bundled into CPT code 76930.
1. The HCPCS/CPT code(s) may be subject to Correct Coding initiative (CCI) edits. This policy does not take precedence over CCI edits. Please refer to the current version CCI for correct coding guidelines and specific applicable code combinations prior to billing Medicare.
2. All procedures related to pain management procedures performed by the physician/provider performed on the same day must be billed on the same claim.
3. An imaging guidance code is billed only once per session for CPT code 77003, fluoroscopy or CPT code 77012 for CT guidance. Physicians may only bill for the professional component when imaging is performed in a hospital or non-office facility. No claim should be submitted for the hard or digital film(s) maintained to document needle placement.
4. The CPT code 72275 (Epidurography, radiological supervision and interpretation) differs from CPT code 77003 in that it represents a formal recorded and reported contrast study that includes fluoroscopy. Epidurography should only be reported when it is reasonable and medically necessary to perform a diagnostic study. Epidurography should not be billed when the contrast injection is part of the fluoroscopic guidance and contrast injection to confirm correct needle placement that is integral to the epidural, transforaminal and intrathecal injections addressed in the policy.
ADVISORY PANEL ON AMBULATORY PAYMENT CLASSIFICATION (APC) GROUPS
The Panel recommends that CMS maintain the packaged status of the following:
• CPT code 76001, Fluoroscopy, physician time more than one hour, assisting a nonradiologic physician (e.g., nephrostolithotomy, ERCP, bronchoscopy, transbronchial biopsy)
• CPT code 76003, Fluoroscopic guidance for needle placement (e.g., biopsy, aspiration, injection, localization device)
• CPT code 76005, Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid, paravertebral facet joint, paravertebral facet joint nerve or sacroiliac joint), including neurolytic agent destruction.
Anthem Central Region Clinical Claims
Subject: Fluoroscopic Guidance for Needle Placement (e.g., Biopsy, Aspiration, Injection, Localization Device) with Magnetic Resonance (e.g., Proton) any Joint of Upper Extremity; with Contrast Material(s) or with Injection Procedure for Shoulder Arthrography or Enhanced CT/MRI Shoulder Arthrography.
76003 (Fluoroscopic guidance for needle placement{e.g., biopsy, aspiration, injection, localization device}) does not bundle with 73222 (Magnetic resonance [e.g., proton}, any joint of upper extremity; with contrast material(s).
76003-26 (Fluoroscopic guidance for needle placement{e.g., biopsy, aspiration, injection, localization device}) does not bundle with 73222-26 (Magnetic resonance [e.g., proton}, any joint of upper extremity; with contrast material(s).
76003-TC (Fluoroscopic guidance for needle placement{e.g., biopsy, aspiration, injection, localization device}) does not bundle with 73222-TC (Magnetic resonance [e.g., proton}, any joint of upper extremity; with contrast material(s).
76003 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350 (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
76003-26 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350-50 (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
76003-26 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350-LT (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
76003 (Fluoroscopic guidance for needle placement {e.g., biopsy, aspiration, injection, localization device}) does not bundle with 23350-RT (Injection procedure for shoulder arthrography or enhanced CT/MRI shoulder arthrography).
Anthem Central Region does not bundle 76003 with 73222, does not bundle 76003-26 with 73222-26, and does not bundle 76003-TC with 73222-TC. Based on CPT article, Coding Clarification, Radiology Procedures, it states:
“It is important to note that MRI obtained after intraarticular administration of contrast (MR arthrography) should be coded as a "with contrast examination." In addition, it is appropriate to report the appropriate procedure code and guidance code (if used) for injection of contrast into the joint. For instance, to report an MRI of the shoulder with intra-articular contrast (MR arthrography of the shoulder), it is appropriate to report 23350 for the shoulder joint injection. You would report 76003 if fluoroscopic guidance was used to guide needle placement into the joint, and 73222 for the MRI shoulder with contrast.”
Based on the National Correct Coding Initiative Edits, code 76003 is not listed as a component code to code 73222. Therefore, if 76003 is submitted with 73222—both reimburse separately, if 76003-26 is submitted with 73222-26—both reimburse separately, if 76003-LT is submitted with 73222-LT—both reimburse separately, if 76003-RT is submitted with 73222-RT—both reimburse separately and if 76003- TC is submitted with 73222-TC—both reimburse separately.
Anthem Central Region does not bundle 76003 with 23350, does not bundle 76003-26 with 23350-50, does not bundle 76003-26 with 23350-LT and does not bundle 76003-26 with 23350-RT. Based on the National Correct Coding Initiative Edits, code 76003 is not listed as a component code to code 23350. Therefore, if 76003 is submitted with 23350—both reimburse separately, if 76003-26 is submitted with 23350-50 .
Whether there should be reimbursement for CPT codes 27299-51, 22899-51, 38230, 95920, 95937 and 76003 for date of service 03-05-04.
RATIONALE
CPT code 27299-51 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). The carrier’s position states that code 27299-51 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg. IX#9. Per Ingenix EncoderPro CPT code 27299-51 is not a global procedure code. Per Rule 133.1(a)(8) fair and reasonable reimbursement – the carrier did not state an amount. Reimbursement is recommended per the Medical Fee Schedule effective 08-01-03 in the amount of $1400.00.
CPT code 22899-51 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). The carrier’s position states that code 22899-51 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg. IX#9. Per Ingenix EncoderPro CPT code 22899-51 is not a global procedure code. Per Rule 133.1(a)(8) fair and reasonable reimbursement – the carrier did not state an amount. Reimbursement is recommended per the Medical Fee Schedule effective 08-01-03 in the amount of $1200.00.
CPT code 38230 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). The carrier’s position states that code 38230 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg. X. Per Ingenix EncoderPro CPT code 38230 is not a global procedure code. The MAR per the Medical Fee
MDR Tracking #: M5-05-0126 01 Schedule effective 08-01-03 is $366.39 ($293.11 X 125%), however the requestor billed $183.19, therefore this is the recommended amount of reimbursement.
CPT codes 95920 and 95937 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement). Per Ingenix EncoderPro CCI edits CPT codes 95920 and 95937 are global to CPT code 22612 which was the primary procedure billed per the EOB. No reimbursement is recommended. CPT code 76003 date of service 03-05-04 denied with denial code “G/X815” (this procedure is incidental to the primary procedure, and does not warrant separate reimbursement).
The carrier’s position states that code 76003 is part of the global service package per the American Academy of Orthopaedic Surgeons-Complete Global Service Data Handbook pg.viii#6. Per Ingenix EncoderPro CPT code 76003 is not a global procedure code. Reimbursement per the Medical Fee Guideline effective 08-01-03 in the amount of $98.08 ($78.46 X 125%) is recommended.
IV. DECISION
Based upon the review of the disputed healthcare services within this request, the Division has determined that the requestor is entitled to reimbursement for CPT codes 27299-51, 22899-51, 38230 and 76003. The Division has determined that the requestor is not entitled to reimbursement for CPT codes 95920 and 95937.
Sample payment amount for Fluoroscopic Imaging Procedures
2007 Medicare Reimbursement for Selected Fluoroscopic Imaging Procedures
(Reflects National Rates, Unadjusted For Locality)
(Reflects National Rates, Unadjusted For Locality)
| CPT/HCPCS Code | Medicare Reimbursement Component | Hospital Inpatient Department | Hospital Outpatient Department | IDTF or Physician Office |
| CPT 77002 Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization device) | Technical | DRG | Packaged | $49.65 |
| Professional | $25.39 | $25.39 | $25.39 | |
| Total | DRG + $25.39 | NA | $75.04 | |
| CPT 77003 Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural, transforaminal epidural, subarachnoid, paravertebral facet joint, paravertebral facet joint nerve or sacroiliac joint), including neurolytic agent destruction | Technical | DRG | Packaged | $45.48 |
| Professional | $27.29 | $27.29 | $27.29 | |
| Total | DRG + $27.29 | NA | $72.77 |
ASC bilateral procedure payment
Bilateral procedures under the revised ASC payment system
How should Ambulatory Surgical Centers (ASCs) report bilateral procedures under the revised ASC payment system?
Bilateral procedures should be reported as a single unit on two separate lines or with “2” in the units field on one line, in order for both procedures to be paid. While use of the -50 modifier is not specifically prohibited according to CMS billing instructions, the modifier will not be recognized for payment purposes and may result in incorrect payment to ASCs. The multiple procedure reduction of 50 percent will apply to all bilateral procedures subject to multiple procedure discounting.
How should Ambulatory Surgical Centers (ASCs) report bilateral procedures under the revised ASC payment system?
Bilateral procedures should be reported as a single unit on two separate lines or with “2” in the units field on one line, in order for both procedures to be paid. While use of the -50 modifier is not specifically prohibited according to CMS billing instructions, the modifier will not be recognized for payment purposes and may result in incorrect payment to ASCs. The multiple procedure reduction of 50 percent will apply to all bilateral procedures subject to multiple procedure discounting.
ASC facility services payment
Medicare makes a single payment to ASCs for covered services, which includes ASC facility services
that are furnished in connection with a covered procedure.
Examples of covered ASC facility services that are paid through the payment for covered surgical
procedures include the following:
• Nursing services, services furnished by technical personnel, and other related services;
• Patient use of ASC facilities;
• Drugs and biologicals for which separate payment is not allowed under the OPPS, surgical
dressings, supplies, splints, casts, appliances, and equipment;
• Administrative, recordkeeping, and housekeeping items and services;
• Blood, blood plasma, and platelets, with the exception of those to which the blood deductible
applies;
• Materials for anesthesia;
• Intraocular lenses;
• Implantable devices, with the exception of those devices with pass-through status under the OPPS;
and
• Radiology services for which payment is packaged under the OPPS
Medicare also pays ASCs separately for covered ancillary services that are integral to a covered
surgical procedure billed by the ASC, specifically certain services that are furnished immediately
before, during, or immediately after the covered surgical procedure. Covered ancillary services include:
• Drugs and biologicals that are separately paid under the OPPS;
• Radiology services that are separately paid under the OPPS;
• Brachytherapy sources;
• Implantable devices with OPPS pass-through status; and
• Corneal tissue acquisition
that are furnished in connection with a covered procedure.
Examples of covered ASC facility services that are paid through the payment for covered surgical
procedures include the following:
• Nursing services, services furnished by technical personnel, and other related services;
• Patient use of ASC facilities;
• Drugs and biologicals for which separate payment is not allowed under the OPPS, surgical
dressings, supplies, splints, casts, appliances, and equipment;
• Administrative, recordkeeping, and housekeeping items and services;
• Blood, blood plasma, and platelets, with the exception of those to which the blood deductible
applies;
• Materials for anesthesia;
• Intraocular lenses;
• Implantable devices, with the exception of those devices with pass-through status under the OPPS;
and
• Radiology services for which payment is packaged under the OPPS
Medicare also pays ASCs separately for covered ancillary services that are integral to a covered
surgical procedure billed by the ASC, specifically certain services that are furnished immediately
before, during, or immediately after the covered surgical procedure. Covered ancillary services include:
• Drugs and biologicals that are separately paid under the OPPS;
• Radiology services that are separately paid under the OPPS;
• Brachytherapy sources;
• Implantable devices with OPPS pass-through status; and
• Corneal tissue acquisition
Payment methodolgy for ASC
Certain services may be furnished in ASCs and billed by the appropriate certified provider or supplier
or, in certain cases, billed by the ASC facility itself and paid outside the ASC payments for covered
surgical procedures or covered ancillary services.
The chart shown here gives examples of payment and billing for items or services that are not included
in the ASC payments for covered surgical procedures or covered ancillary services.
Beginning in CY 2008, about 3,400 procedures are approved for ASC payment and categorized into
one of several hundred payment groups. In the November 2007 OPPS/ASC final rule, the budget
neutrality adjustment for CY 2008 is 65 percent of the OPPS payment rates for the same surgical
procedures.
Beginning in CY 2008, there will be a four-year transition period for implementation of the revised ASC
payment system, with the exception of Healthcare Common Procedure Coding System codes newly
payable in the ASC setting, as described below:
• CY 2008—Payment rates will consist of 25 percent of the CY 2008 revised ASC rate plus 75
percent of the CY 2007 ASC rate;
• CY 2009—Payment rates will consist of 50 percent of the CY 2008 revised ASC rate plus 50
percent of the CY 2007 ASC rate;
• CY 2010—Payment rates will consist of 75 percent of the CY 2008 revised ASC rate plus 25
percent of the CY 2007 ASC rate; and
• Beginning in CY 2011—Payment rates will be calculated according to policies of the revised
payment system.
Modified payment methodologies will be used to establish ASC payment rates for new, office-based
procedures, device-intensive procedures, separately payable radiology services, separately payable
drugs and biologicals, and brachytherapy sources.
or, in certain cases, billed by the ASC facility itself and paid outside the ASC payments for covered
surgical procedures or covered ancillary services.
The chart shown here gives examples of payment and billing for items or services that are not included
in the ASC payments for covered surgical procedures or covered ancillary services.
Beginning in CY 2008, about 3,400 procedures are approved for ASC payment and categorized into
one of several hundred payment groups. In the November 2007 OPPS/ASC final rule, the budget
neutrality adjustment for CY 2008 is 65 percent of the OPPS payment rates for the same surgical
procedures.
Beginning in CY 2008, there will be a four-year transition period for implementation of the revised ASC
payment system, with the exception of Healthcare Common Procedure Coding System codes newly
payable in the ASC setting, as described below:
• CY 2008—Payment rates will consist of 25 percent of the CY 2008 revised ASC rate plus 75
percent of the CY 2007 ASC rate;
• CY 2009—Payment rates will consist of 50 percent of the CY 2008 revised ASC rate plus 50
percent of the CY 2007 ASC rate;
• CY 2010—Payment rates will consist of 75 percent of the CY 2008 revised ASC rate plus 25
percent of the CY 2007 ASC rate; and
• Beginning in CY 2011—Payment rates will be calculated according to policies of the revised
payment system.
Modified payment methodologies will be used to establish ASC payment rates for new, office-based
procedures, device-intensive procedures, separately payable radiology services, separately payable
drugs and biologicals, and brachytherapy sources.
Thursday, June 24, 2010
Payment For Presbyopia-Correcting Intraocular Lens (P-C IOL) and Astigmatism-Correcting Intraocular Lens (A-C IOLs)
Payment For Presbyopia-Correcting Intraocular Lens (P-C IOL) and Astigmatism-Correcting Intraocular Lens (A-C IOLs)
Medicare will allow beneficiaries to pay additional charges associated with insertion of a P-C IOL or A-C IOL following the extraction of a cataract:
• There is no Medicare benefit category that allows payment of facility charges for services and supplies required to insert and adjust a P-C IOL or A-C IOL following removal of a cataract that exceed the facility charges for services and supplies required for the insertion and adjustment of a conventional IOL.
• There is no Medicare benefit category that allows payment of facility charges for subsequent treatments, services and supplies required to examine and monitor the beneficiary who receives a P-C IOL or A-C IOL following removal of a cataract that exceeds the facility charges for subsequent treatments, services and supplies required to examine and monitor a beneficiary after cataract surgery followed by insertion of a conventional IOL.
When a beneficiary requests insertion of a P-C IOL or A-C IOL instead of a conventional IOL following removal of a cataract:
• Prior to the procedure to remove a cataract and insert a P-C IOL or A-C IOL, the facility and the physician must inform the beneficiary that Medicare will not make payment for services that are specific to the insertion, adjustment or other subsequent treatments related to the P-C or A-C functionality of the IOL.
•
The P-C or A-C functionality of a IOL does not fall into a Medicare benefit category, and, therefore, is not covered. Therefore, the facility and physician are not required to provide an Advanced Beneficiary Notice to beneficiaries who request a P-C or A-C IOL.
•
Although not required, NHIC strongly encourages facilities and physicians to issue a Notice of Exclusion from Medicare Benefits to beneficiaries in order to clearly identify the non-payable aspects of a P-C or A-C IOL insertion.
When a beneficiary requests insertion of a P-C or A-C IOL instead of a conventional IOL following removal of a cataract and that procedure is performed, the beneficiary is responsible for payment of facility and physician charges for services and supplies attributable to the P-C or A-C functionality of the IOL:
• In determining the beneficiary's liability, the facility and physician may take into account any additional work and resources required for insertion, fitting, vision acuity testing, and monitoring of the P-C or A-C IOL that exceed the work and resources attributable to insertion of a conventional IOL.
Medicare will allow beneficiaries to pay additional charges associated with insertion of a P-C IOL or A-C IOL following the extraction of a cataract:
• There is no Medicare benefit category that allows payment of facility charges for services and supplies required to insert and adjust a P-C IOL or A-C IOL following removal of a cataract that exceed the facility charges for services and supplies required for the insertion and adjustment of a conventional IOL.
• There is no Medicare benefit category that allows payment of facility charges for subsequent treatments, services and supplies required to examine and monitor the beneficiary who receives a P-C IOL or A-C IOL following removal of a cataract that exceeds the facility charges for subsequent treatments, services and supplies required to examine and monitor a beneficiary after cataract surgery followed by insertion of a conventional IOL.
When a beneficiary requests insertion of a P-C IOL or A-C IOL instead of a conventional IOL following removal of a cataract:
• Prior to the procedure to remove a cataract and insert a P-C IOL or A-C IOL, the facility and the physician must inform the beneficiary that Medicare will not make payment for services that are specific to the insertion, adjustment or other subsequent treatments related to the P-C or A-C functionality of the IOL.
•
The P-C or A-C functionality of a IOL does not fall into a Medicare benefit category, and, therefore, is not covered. Therefore, the facility and physician are not required to provide an Advanced Beneficiary Notice to beneficiaries who request a P-C or A-C IOL.
•
Although not required, NHIC strongly encourages facilities and physicians to issue a Notice of Exclusion from Medicare Benefits to beneficiaries in order to clearly identify the non-payable aspects of a P-C or A-C IOL insertion.
When a beneficiary requests insertion of a P-C or A-C IOL instead of a conventional IOL following removal of a cataract and that procedure is performed, the beneficiary is responsible for payment of facility and physician charges for services and supplies attributable to the P-C or A-C functionality of the IOL:
• In determining the beneficiary's liability, the facility and physician may take into account any additional work and resources required for insertion, fitting, vision acuity testing, and monitoring of the P-C or A-C IOL that exceed the work and resources attributable to insertion of a conventional IOL.
Bundled CPT codes
Rebundling of CPT Codes
The national correct coding initiative (NCCI) rebundling instructions apply to processing claims from ASC facilities. In general, if an ASC bills a CPT code that is considered to be part of another more comprehensive code that is also billed for the same beneficiary on the same date of service, only the more comprehensive code is covered, provided that code is on the list of ASC approved codes.
Payment for Corneal Tissue
For dates of service prior to January 1, 2008, payment for corneal tissue used in an approved ASC procedure is separately payable to either the ASC or surgeon. Effective January 1, 2008, payment for corneal tissue is separately payable only to the ASC. Procedure code V2785 (processing, preserving, and transporting corneal tissue) must be used to report this service. A copy of the invoice from the eye bank which provided the corneal tissue is required.
Note: Providers must provide the invoice upon request.
Payment for Intraocular Lens (IOL)
The procedures that include insertion of an IOL are CPT codes 66982,66983, 66984, 66985, and 66986. Prior to January 1, 2008, payment for facility services furnished by an ASC for IOL insertion during or subsequent to cataract surgery includes an allowance for the lens. The ASC payment system logic that excluded $150 for IOLs for purposes of the multiple surgery reduction in cases of cataract surgery no longer applies. Beginning January 1, 2008, the Medicare payment for the IOL is included in the Medicare ASC payment for the associated surgical procedure. ASCs should not report separate charges for conventional IOLs because their payment is included in the Medicare payment for the associated surgical procedure.
Payment for New Technology Intraocular Lenses (NTIOLs)
Effective for dates of service on and after February 27, 2006, through February 26, 2011, Medicare will pay an additional $50 for Category 3 NTIOLs. HCPCS code Q1003 has been created to bill for the additional $50. Q1003 shall be billed on the same claim as the surgical insertion procedure.
Any subsequent IOLs recognized by CMS as having the same characteristics as the first IOL recognized by CMS for a payment adjustment (those of reduced spherical aberration-Category 3) will receive the same adjustment for the remainder of the 5-year period established by the first recognized IOL. Contractors and providers will be aware that HCPCS Q1003, along with one of the approved procedures codes (66982, 66983, 66984, 66985, and 66986) are to be used on all Category 3 NTIOL claims associated with reduced spherical aberration from February 27, 2006, through February 26, 2011. The list of Category 3 NTIOLs is available on the CMS Web site at:
http://www.cms.hhs.gov/ASCPayment/08_NTIOLs.asp#TopOfPage.
Medicare contractors:
• Shall return as unprocessable any claims for NTIOLs containing Q1003 alone or with a code other than one of the above listed procedure codes.
• Shall deny payment for Q1003 if services are furnished in a facility other than a Medicare-approved ASC.
• Shall deny payment for Q1003 if billed by an entity other than a Medicare-approved ASC.
The national correct coding initiative (NCCI) rebundling instructions apply to processing claims from ASC facilities. In general, if an ASC bills a CPT code that is considered to be part of another more comprehensive code that is also billed for the same beneficiary on the same date of service, only the more comprehensive code is covered, provided that code is on the list of ASC approved codes.
Payment for Corneal Tissue
For dates of service prior to January 1, 2008, payment for corneal tissue used in an approved ASC procedure is separately payable to either the ASC or surgeon. Effective January 1, 2008, payment for corneal tissue is separately payable only to the ASC. Procedure code V2785 (processing, preserving, and transporting corneal tissue) must be used to report this service. A copy of the invoice from the eye bank which provided the corneal tissue is required.
Note: Providers must provide the invoice upon request.
Payment for Intraocular Lens (IOL)
The procedures that include insertion of an IOL are CPT codes 66982,66983, 66984, 66985, and 66986. Prior to January 1, 2008, payment for facility services furnished by an ASC for IOL insertion during or subsequent to cataract surgery includes an allowance for the lens. The ASC payment system logic that excluded $150 for IOLs for purposes of the multiple surgery reduction in cases of cataract surgery no longer applies. Beginning January 1, 2008, the Medicare payment for the IOL is included in the Medicare ASC payment for the associated surgical procedure. ASCs should not report separate charges for conventional IOLs because their payment is included in the Medicare payment for the associated surgical procedure.
Payment for New Technology Intraocular Lenses (NTIOLs)
Effective for dates of service on and after February 27, 2006, through February 26, 2011, Medicare will pay an additional $50 for Category 3 NTIOLs. HCPCS code Q1003 has been created to bill for the additional $50. Q1003 shall be billed on the same claim as the surgical insertion procedure.
Any subsequent IOLs recognized by CMS as having the same characteristics as the first IOL recognized by CMS for a payment adjustment (those of reduced spherical aberration-Category 3) will receive the same adjustment for the remainder of the 5-year period established by the first recognized IOL. Contractors and providers will be aware that HCPCS Q1003, along with one of the approved procedures codes (66982, 66983, 66984, 66985, and 66986) are to be used on all Category 3 NTIOL claims associated with reduced spherical aberration from February 27, 2006, through February 26, 2011. The list of Category 3 NTIOLs is available on the CMS Web site at:
http://www.cms.hhs.gov/ASCPayment/08_NTIOLs.asp#TopOfPage.
Medicare contractors:
• Shall return as unprocessable any claims for NTIOLs containing Q1003 alone or with a code other than one of the above listed procedure codes.
• Shall deny payment for Q1003 if services are furnished in a facility other than a Medicare-approved ASC.
• Shall deny payment for Q1003 if billed by an entity other than a Medicare-approved ASC.
Physician ASC service payment
CODING AND REIMBURSEMENT
Physician Services
Physicians’ services include the services of anesthesiologists administering or supervising the administration of anesthesia to ASC patients and the patients’ recovery from the anesthesia. The term physicians’ services also includes any routine pre- or postoperative services, such as office visits, consultations, diagnostic tests, removal of stitches, changing of dressings, and other services which the individual physician usually performs.
The carrier pays the facility fee from the MPFS to the physician. The facility fee is for services done in a facility other than the physician’s office and is less than the nonfacility fee for services performed in the physician’s office. Physician services for ASC surgical services will be reimbursed at 80% of the Medicare Physician Fee Schedule (MPFS) with deductible and coinsurance applied.
Note: For procedures with dates of service prior to January 1, 2008, the carrier pays the nonfacility fee from the MPFS to the physician for codes not on the ASC list.
Use place of service code 24 (Ambulatory Surgical Center) for physician charges for services provided in the ASC facility. The Medicare global fee policies will be applied to physician services provided in an ASC. In a past audit of claims processed by NHIC , the Office of Inspector General (OIG) discovered that physicians incorrectly coded the place of service on 81 of 100 sampled claims by using the “office” place of service even though they performed the services in an outpatient hospital setting or an ambulatory surgical center. This resulted in an overpayment to the physician. Medicare has established different RVUs (Relative Value Units) for services performed in a facility versus a nonfacility setting. The correct place of service code ensures that Medicare is not duplicating payment to the physician and the facility for any part of the practice expense incurred to perform a Medicare service. The payments to the physicians are higher when the services are performed in non-facility settings.
Physicians are required to submit a separate claim for their professional service. Under no circumstances should a physician’s bill for their professional services be included on the same claim as the ASC facility charge.
Note: Although the physician can be reimbursed for a procedure performed in an ASC not on the ASC list, no facility payment will be made to the ASC.
Physician Services
Physicians’ services include the services of anesthesiologists administering or supervising the administration of anesthesia to ASC patients and the patients’ recovery from the anesthesia. The term physicians’ services also includes any routine pre- or postoperative services, such as office visits, consultations, diagnostic tests, removal of stitches, changing of dressings, and other services which the individual physician usually performs.
The carrier pays the facility fee from the MPFS to the physician. The facility fee is for services done in a facility other than the physician’s office and is less than the nonfacility fee for services performed in the physician’s office. Physician services for ASC surgical services will be reimbursed at 80% of the Medicare Physician Fee Schedule (MPFS) with deductible and coinsurance applied.
Note: For procedures with dates of service prior to January 1, 2008, the carrier pays the nonfacility fee from the MPFS to the physician for codes not on the ASC list.
Use place of service code 24 (Ambulatory Surgical Center) for physician charges for services provided in the ASC facility. The Medicare global fee policies will be applied to physician services provided in an ASC. In a past audit of claims processed by NHIC , the Office of Inspector General (OIG) discovered that physicians incorrectly coded the place of service on 81 of 100 sampled claims by using the “office” place of service even though they performed the services in an outpatient hospital setting or an ambulatory surgical center. This resulted in an overpayment to the physician. Medicare has established different RVUs (Relative Value Units) for services performed in a facility versus a nonfacility setting. The correct place of service code ensures that Medicare is not duplicating payment to the physician and the facility for any part of the practice expense incurred to perform a Medicare service. The payments to the physicians are higher when the services are performed in non-facility settings.
Physicians are required to submit a separate claim for their professional service. Under no circumstances should a physician’s bill for their professional services be included on the same claim as the ASC facility charge.
Note: Although the physician can be reimbursed for a procedure performed in an ASC not on the ASC list, no facility payment will be made to the ASC.
CODING AND REIMBURSEMENT for ASC facility and pyhsician
CODING AND REIMBURSEMENT
Facility and Physician Allowance
Generally, there are two primary elements in the total cost of performing a surgical procedure:
• Cost of the physician’s professional services for performing the procedure; and
• Cost of services furnished by the facility where the procedure is performed (for example, surgical supplies, equipment, and nursing services).
The professional fee is paid to the physician; the facility fee is paid to the ASC. Physician coding and ASC coding of the procedures performed should match.
Facility Services
Prior to January 1, 2008:
The ASC payment rate is a standard overhead amount based on CMS’s estimate of a fair fee and the costs incurred by the ASCs providing the procedure. The HCPCS procedures for services covered by the ASC are grouped into pricer groups and a rate is set for each group. The ASC payment rates for each ASC covered procedure is based on the payment rates for the pricer groups, but capped at the hospital outpatient prospective payment system (OPPS) payment rate for the procedure. The Metropolitan Statistical Areas (MSAs) are used as the basis for ASC wage adjustments.
Effective January 1, 2008:
With implementation of the revised ASC payment system, the payment rates for most covered ASC surgical procedures and covered ancillary services are established prospectively based on a percentage of the hospital OPPS rates. There is an annual adjustment of the payment rates for inflation. The update for inflation begins with the CY 2010 ASC payment rates when the statutory requirement for a zero update no longer applies.
CMS adjusts for geographic differences in wages using the Core Based Statistical Area geographic locality definitions established in 2003 by the Office of Management and Budget (OMB).
ASC facility services are subject to the usual Medicare Part B deductible and coinsurance requirements. In general, the Medicare program pays ASCs 80 percent of the lesser of the actual charge or the ASC facility payment rate for the covered services performed. The beneficiary pays 20 percent of the lesser of the submitted charge or the ASC facility payment rate for the covered services performed.
EXCEPTION on coinsurance and deductible: Effective for colorectal cancer screening colonoscopies (G0105 and G0121) performed on and after January 1, 2007, there is no deductible and a 25 percent coinsurance payment applies.
Facility and Physician Allowance
Generally, there are two primary elements in the total cost of performing a surgical procedure:
• Cost of the physician’s professional services for performing the procedure; and
• Cost of services furnished by the facility where the procedure is performed (for example, surgical supplies, equipment, and nursing services).
The professional fee is paid to the physician; the facility fee is paid to the ASC. Physician coding and ASC coding of the procedures performed should match.
Facility Services
Prior to January 1, 2008:
The ASC payment rate is a standard overhead amount based on CMS’s estimate of a fair fee and the costs incurred by the ASCs providing the procedure. The HCPCS procedures for services covered by the ASC are grouped into pricer groups and a rate is set for each group. The ASC payment rates for each ASC covered procedure is based on the payment rates for the pricer groups, but capped at the hospital outpatient prospective payment system (OPPS) payment rate for the procedure. The Metropolitan Statistical Areas (MSAs) are used as the basis for ASC wage adjustments.
Effective January 1, 2008:
With implementation of the revised ASC payment system, the payment rates for most covered ASC surgical procedures and covered ancillary services are established prospectively based on a percentage of the hospital OPPS rates. There is an annual adjustment of the payment rates for inflation. The update for inflation begins with the CY 2010 ASC payment rates when the statutory requirement for a zero update no longer applies.
CMS adjusts for geographic differences in wages using the Core Based Statistical Area geographic locality definitions established in 2003 by the Office of Management and Budget (OMB).
ASC facility services are subject to the usual Medicare Part B deductible and coinsurance requirements. In general, the Medicare program pays ASCs 80 percent of the lesser of the actual charge or the ASC facility payment rate for the covered services performed. The beneficiary pays 20 percent of the lesser of the submitted charge or the ASC facility payment rate for the covered services performed.
EXCEPTION on coinsurance and deductible: Effective for colorectal cancer screening colonoscopies (G0105 and G0121) performed on and after January 1, 2007, there is no deductible and a 25 percent coinsurance payment applies.
COVERAGE OF SERVICES IN AN ASC
COVERAGE OF SERVICES IN AN ASC WHICH ARE NOT ASC FACILITY SERVICES
• Ambulance Services
If the ASC furnishes ambulance services, the facility may obtain approval as an ambulance supplier to bill covered ambulance services.
• Artificial Legs, Arms and Eyes
Like non-implantable prosthetic devices and braces, this equipment is not considered part of an ASC facility service and so is not included in the ASC facility payment rate. If the ASC furnishes these items to patients, it is treated as a DME supplier, and all the rules and conditions ordinarily applicable to suppliers are applicable, including obtaining a supplier number and billing the DME MAC where applicable.
• Durable Medical Equipment (DME) (Implantable)
If the ASC furnishes items of implantable DME to patients, the ASC bills and receives a single payment from NHIC for the covered surgical procedure and the implantable device, as long as the implantable device does not have pass-through status under the OPPS. When the surgical procedure is not on the ASC list, the physician bills for his or her professional services and the ASC may bill the beneficiary for the facility charges associated with the procedure.
• Durable Medical Equipment (DME) (Non-implantable)
If the ASC furnishes items of non-implantable DME to patients, the ASC is treated as a DME supplier and all rules and conditions ordinarily applicable to DME are applicable. This includes obtaining a supplier number and billing the DME MAC where applicable.
• Leg, Arm, Back and Neck Braces
These items of equipment, like non-implantable prosthetic devices, are covered under Part B, but are not included in the ASC facility payment amount. If the ASC furnishes these to patients, it is treated as a DME supplier, and all the rules and conditions ordinarily applicable to suppliers are applicable, including obtaining a supplier number and billing the DME MAC where applicable.
• Physicians’ Services
This category includes most covered services performed in ASCs which are not considered ASC facility services. Consequently, physicians who perform covered services in ASCs receive separate payment under Part B. Physicians’ services include the services of anesthesiologists administering or supervising the administration of anesthesia to ASC patients and the patients’ recovery from the anesthesia. The term physicians’ services also includes any routine pre- or post- operative services, such as office visits, consultations, diagnostic tests, removal of stitches, changing of dressings, and other services which the individual physician usually includes in the fee for a given surgical procedure.
• Prosthetic Devices
Prior to January 1, 2008, an ASC was allowed to bill and receive separate payment for implantable prosthetic devices, other than intraocular lenses (IOLs) that were implanted, inserted, or otherwise applied by surgical procedures on the ASC list of approved procedures. The ASC billed NHIC and received payment according to the DMEPOS fee schedule. However, an intraocular lens (IOL) inserted during or subsequent to cataract surgery in an ASC was included in the facility payment rate.
Beginning January 1, 2008, payment for implantable prosthetic devices without OPPS pass-through status is included in the ASC payment for the covered surgical procedure. ASCs may not bill separately for implantable devices without OPPS pass-through status. If the ASC furnishes non-implantable prosthetic devices to beneficiaries, the ASC is treated as a supplier, and all the rules and conditions ordinarily applicable to suppliers are applicable, including obtaining a supplier number and billing as directed by the jurisdiction list.
• Services of an Independent Laboratory
Only a very limited number and type of diagnostic tests are considered ASC facility services and these are included in the ASC facility payment rate. In most cases, diagnostic tests performed directly by an ASC are not considered ASC facility services, and are not covered under Medicare since §1861(s) of the statute limits coverage of diagnostic lab tests in facilities other than physicians’ offices, rural health clinics or hospitals to facilities that meet the statutory definition of an independent laboratory. The ASC’s laboratory must be CLIA certified and will need to enroll with NHIC as a laboratory. Otherwise, the ASC makes arrangements with a covered laboratory or laboratories for laboratory services. If the ASC has a certified independent laboratory, the laboratory itself bills NHIC.
• Ambulance Services
If the ASC furnishes ambulance services, the facility may obtain approval as an ambulance supplier to bill covered ambulance services.
• Artificial Legs, Arms and Eyes
Like non-implantable prosthetic devices and braces, this equipment is not considered part of an ASC facility service and so is not included in the ASC facility payment rate. If the ASC furnishes these items to patients, it is treated as a DME supplier, and all the rules and conditions ordinarily applicable to suppliers are applicable, including obtaining a supplier number and billing the DME MAC where applicable.
• Durable Medical Equipment (DME) (Implantable)
If the ASC furnishes items of implantable DME to patients, the ASC bills and receives a single payment from NHIC for the covered surgical procedure and the implantable device, as long as the implantable device does not have pass-through status under the OPPS. When the surgical procedure is not on the ASC list, the physician bills for his or her professional services and the ASC may bill the beneficiary for the facility charges associated with the procedure.
• Durable Medical Equipment (DME) (Non-implantable)
If the ASC furnishes items of non-implantable DME to patients, the ASC is treated as a DME supplier and all rules and conditions ordinarily applicable to DME are applicable. This includes obtaining a supplier number and billing the DME MAC where applicable.
• Leg, Arm, Back and Neck Braces
These items of equipment, like non-implantable prosthetic devices, are covered under Part B, but are not included in the ASC facility payment amount. If the ASC furnishes these to patients, it is treated as a DME supplier, and all the rules and conditions ordinarily applicable to suppliers are applicable, including obtaining a supplier number and billing the DME MAC where applicable.
• Physicians’ Services
This category includes most covered services performed in ASCs which are not considered ASC facility services. Consequently, physicians who perform covered services in ASCs receive separate payment under Part B. Physicians’ services include the services of anesthesiologists administering or supervising the administration of anesthesia to ASC patients and the patients’ recovery from the anesthesia. The term physicians’ services also includes any routine pre- or post- operative services, such as office visits, consultations, diagnostic tests, removal of stitches, changing of dressings, and other services which the individual physician usually includes in the fee for a given surgical procedure.
• Prosthetic Devices
Prior to January 1, 2008, an ASC was allowed to bill and receive separate payment for implantable prosthetic devices, other than intraocular lenses (IOLs) that were implanted, inserted, or otherwise applied by surgical procedures on the ASC list of approved procedures. The ASC billed NHIC and received payment according to the DMEPOS fee schedule. However, an intraocular lens (IOL) inserted during or subsequent to cataract surgery in an ASC was included in the facility payment rate.
Beginning January 1, 2008, payment for implantable prosthetic devices without OPPS pass-through status is included in the ASC payment for the covered surgical procedure. ASCs may not bill separately for implantable devices without OPPS pass-through status. If the ASC furnishes non-implantable prosthetic devices to beneficiaries, the ASC is treated as a supplier, and all the rules and conditions ordinarily applicable to suppliers are applicable, including obtaining a supplier number and billing as directed by the jurisdiction list.
• Services of an Independent Laboratory
Only a very limited number and type of diagnostic tests are considered ASC facility services and these are included in the ASC facility payment rate. In most cases, diagnostic tests performed directly by an ASC are not considered ASC facility services, and are not covered under Medicare since §1861(s) of the statute limits coverage of diagnostic lab tests in facilities other than physicians’ offices, rural health clinics or hospitals to facilities that meet the statutory definition of an independent laboratory. The ASC’s laboratory must be CLIA certified and will need to enroll with NHIC as a laboratory. Otherwise, the ASC makes arrangements with a covered laboratory or laboratories for laboratory services. If the ASC has a certified independent laboratory, the laboratory itself bills NHIC.
SERVICES FURNISHED IN AN ASC WHICH ARE NOT ASC FACILITY SERVICES
A single payment is made to an ASC which includes all facility services furnished by the ASC in connection with a covered procedure. However, a number of items and services covered under Medicare may be furnished in an ASC which are not considered facility services, and which the ASC payment does not include. These non-ASC services are covered and paid for under the applicable provisions of Part B. In addition, the ASC may be part of a medical complex that includes other entities, such as an independent laboratory, supplier of durable medical equipment, or a physician’s office, which are covered as separate entities under Part B. In general, an item or service provided in a separate part of the complex is not considered an ASC service, except as defined above. Following is a chart as to who may receive payment and where to submit the bill.
Examples of payment and billing for items or services that are not ASC facility services for claims with dates of service prior to January 1, 2008.
| Items NOT Included in the ASC Facility Rate | Who May Receive Payment | Submit Bills To: |
| Physicians’ services | Physician | A/B MAC |
| The purchase or rental of non- implantable durable medical equipment (DME) to ASC patients for use in their homes | Supplier NOTE: An ASC can be a supplier of DME if it has a supplier number from the National Supplier Clearinghouse | DME MAC |
| Implantable DME and accessories | ASC | A/B MAC |
| Non-implantable prosthetic devices | Supplier | DME MAC |
| Implantable prosthetic devices except certain intraocular lenses (IOLs and NTIOLs), and accessories | ASC | A/B MAC |
| Ambulance services | Certified Ambulance supplier | A/B MAC |
| Leg, arm, back, and neck braces | Supplier | DME MAC |
| Artificial legs, arms, and eyes | Supplier | DME MAC |
| Services furnished by an independent laboratory | Certified lab. ASCs can receive lab certification and a CLIA number. | A/B MAC |
| Procedures NOT on the ASC list | Physician | Physician bills A/B MAC for procedure and any implantable prosthetics/DME. ASC bills beneficiary for facility charges associated with the non-covered procedure |
Examples of payment and billing for items or services that are ASC facility services for claims with dates of service effective January 1, 2008.
| Items Included in the ASC Facility Rate | Who May Receive Payment | Submit Bills To: |
| Implantable DME and accessories without OPPS pass-through status | ASC | A/B MAC |
| Implantable nonpass-through prosthetic devices (except NTIOLs) and accessories without OPPS pass-through status | ASC | A/B MAC |
| Drugs and biologicals for which there is no separate OPPS payment | ASC | A/B MAC |
Covered ancillary services:
ancillary services
Auxiliary or supplemental services, such as diagnostic services, home health services, physical therapy and occupational therapy, used to support diagnosis and treatment of a patient's condition.
Covered ancillary services:
Effective January 1, 2008:
Covered ancillary items and services that are integral to a covered surgical procedure, and for which separate payment to the ASC is allowed are identified below.
Covered ancillary services:
• Brachytherapy sources;
• Certain implantable items that have pass-through status under the OPPS;
• Certain items and services that CMS designates as contractor-priced, including, but not limited to, the procurement of corneal tissue;
• Certain drugs and biologicals for which separate payment is allowed under the OPPS;
• Certain radiology services for which separate payment is allowed under the OPPS.
Definitions of covered ASC facility services include:
• Administrative, Recordkeeping and Housekeeping Items and Services
These include the general administrative functions necessary to run the facility e.g., scheduling, cleaning, utilities, and rent.
• Anesthesia Materials
These include the anesthetic itself, and any materials, whether disposable or re-usable, necessary for its administration.
• Blood, Blood Plasma, Platelets, etc., Except Those to Which Blood Deductible Applies
While covered procedures are limited to those not expected to result in extensive loss of blood, in some cases, blood or blood products are required. Usually the blood deductible results in no expenses for blood or blood products being included under this provision. However, where there is a need for blood or blood products beyond the deductible, they are considered ASC facility services and no separate charge is permitted to the beneficiary or the program.
• Diagnostic or Therapeutic Items and Services
These are items and services furnished by ASC staff in connection with covered surgical procedures. Many ASCs perform diagnostic tests prior to surgery that are generally included in the facility charges, such as urinalysis, blood hemoglobin, hematocrit levels, etc. To the extent that such simple tests are included in the ASC’s facility charges, they are considered facility services. However, under the Medicare program, diagnostic tests are not covered in laboratories independent of a physician’s office, rural health clinic, or hospital unless the laboratories meet the regulatory requirements for the conditions for coverage of services of independent laboratories. Therefore, diagnostic tests performed by the ASC other than those generally included in the facility’s charge are not covered under Part B and are not to be billed as diagnostic tests. If the ASC has its laboratory certified, the laboratory itself may bill for the tests performed.
The ASC may make arrangements with an independent laboratory or other laboratory, such as a hospital laboratory, to perform diagnostic tests it requires prior to surgery. In general, however, the necessary laboratory tests are done outside the ASC prior to scheduling of surgery, since the test results often determine whether the beneficiary should have the surgery done on an outpatient basis in the first place.
• Drugs, Biologicals, Surgical Dressings, Supplies, Splints, Casts, Appliances, and Equipment
This category includes all supplies and equipment commonly furnished by the ASC in connection with surgical procedures. See the following paragraphs for certain exceptions. Drugs and biologicals are limited to those which cannot be self-administered.
Under Part B, coverage for surgical dressings is limited to primary dressings, i.e., therapeutic and protective coverings applied directly to lesions on the skin or on openings to the skin required as the result of surgical procedures. (Items such as Ace bandages, elastic stockings and support hose, Spence boots and other foot coverings, leotards, knee supports, surgical leggings, gauntlets and pressure garments for the arms and hands are used as secondary coverings and therefore are not covered as surgical dressings.) Although surgical dressings usually are covered as “incident to” a physician’s service in a physician’s office setting, in the ASC setting, such dressings are included in the facility’s services.
However, surgical dressings may be reapplied later by others, including the patient or a member of his family. When surgical dressings are obtained by the patient on a physician’s order from a supplier, e.g., a drugstore, the surgical dressing is covered under Part B and paid by the Durable Medical
Equipment Medicare Administrative Contractor (DME MAC).
Similarly, “other supplies, splints, and casts” include only those furnished by the ASC at the time of the surgery. Additional covered supplies and materials furnished later are generally furnished as “incident to” a physician’s service, not as an ASC facility service. The term “supplies” includes those required for both the patient and ASC personnel, e.g., gowns, masks, drapes, hoses, and scalpels, whether disposable or reusable. These are included in the rate for the surgical procedure.
Auxiliary or supplemental services, such as diagnostic services, home health services, physical therapy and occupational therapy, used to support diagnosis and treatment of a patient's condition.
Covered ancillary services:
Effective January 1, 2008:
Covered ancillary items and services that are integral to a covered surgical procedure, and for which separate payment to the ASC is allowed are identified below.
Covered ancillary services:
• Brachytherapy sources;
• Certain implantable items that have pass-through status under the OPPS;
• Certain items and services that CMS designates as contractor-priced, including, but not limited to, the procurement of corneal tissue;
• Certain drugs and biologicals for which separate payment is allowed under the OPPS;
• Certain radiology services for which separate payment is allowed under the OPPS.
Definitions of covered ASC facility services include:
• Administrative, Recordkeeping and Housekeeping Items and Services
These include the general administrative functions necessary to run the facility e.g., scheduling, cleaning, utilities, and rent.
• Anesthesia Materials
These include the anesthetic itself, and any materials, whether disposable or re-usable, necessary for its administration.
• Blood, Blood Plasma, Platelets, etc., Except Those to Which Blood Deductible Applies
While covered procedures are limited to those not expected to result in extensive loss of blood, in some cases, blood or blood products are required. Usually the blood deductible results in no expenses for blood or blood products being included under this provision. However, where there is a need for blood or blood products beyond the deductible, they are considered ASC facility services and no separate charge is permitted to the beneficiary or the program.
• Diagnostic or Therapeutic Items and Services
These are items and services furnished by ASC staff in connection with covered surgical procedures. Many ASCs perform diagnostic tests prior to surgery that are generally included in the facility charges, such as urinalysis, blood hemoglobin, hematocrit levels, etc. To the extent that such simple tests are included in the ASC’s facility charges, they are considered facility services. However, under the Medicare program, diagnostic tests are not covered in laboratories independent of a physician’s office, rural health clinic, or hospital unless the laboratories meet the regulatory requirements for the conditions for coverage of services of independent laboratories. Therefore, diagnostic tests performed by the ASC other than those generally included in the facility’s charge are not covered under Part B and are not to be billed as diagnostic tests. If the ASC has its laboratory certified, the laboratory itself may bill for the tests performed.
The ASC may make arrangements with an independent laboratory or other laboratory, such as a hospital laboratory, to perform diagnostic tests it requires prior to surgery. In general, however, the necessary laboratory tests are done outside the ASC prior to scheduling of surgery, since the test results often determine whether the beneficiary should have the surgery done on an outpatient basis in the first place.
• Drugs, Biologicals, Surgical Dressings, Supplies, Splints, Casts, Appliances, and Equipment
This category includes all supplies and equipment commonly furnished by the ASC in connection with surgical procedures. See the following paragraphs for certain exceptions. Drugs and biologicals are limited to those which cannot be self-administered.
Under Part B, coverage for surgical dressings is limited to primary dressings, i.e., therapeutic and protective coverings applied directly to lesions on the skin or on openings to the skin required as the result of surgical procedures. (Items such as Ace bandages, elastic stockings and support hose, Spence boots and other foot coverings, leotards, knee supports, surgical leggings, gauntlets and pressure garments for the arms and hands are used as secondary coverings and therefore are not covered as surgical dressings.) Although surgical dressings usually are covered as “incident to” a physician’s service in a physician’s office setting, in the ASC setting, such dressings are included in the facility’s services.
However, surgical dressings may be reapplied later by others, including the patient or a member of his family. When surgical dressings are obtained by the patient on a physician’s order from a supplier, e.g., a drugstore, the surgical dressing is covered under Part B and paid by the Durable Medical
Equipment Medicare Administrative Contractor (DME MAC).
Similarly, “other supplies, splints, and casts” include only those furnished by the ASC at the time of the surgery. Additional covered supplies and materials furnished later are generally furnished as “incident to” a physician’s service, not as an ASC facility service. The term “supplies” includes those required for both the patient and ASC personnel, e.g., gowns, masks, drapes, hoses, and scalpels, whether disposable or reusable. These are included in the rate for the surgical procedure.
What are the services included in ASC
ASC SERVICES INCLUDED ON ASC LIST
The ASC payment rate includes only the specifically identified ASC services, included on the ASC payment list. All other non-ASC services such as physician services, prosthetic devices, etc. may be covered and separately billable under Medicare Part B. The Medicare definition of covered facility services for a covered surgical procedure includes services that would be covered if furnished on an inpatient or outpatient basis in connection with a covered surgical procedure. This includes operating and recovery rooms, patient preparation areas, waiting rooms, and other areas used by the patient or offered for use to patient’s needing surgical procedures. It includes all services and procedures provided in connection with covered surgical procedures furnished by nurses, technical personnel and others involved in patient’s care. These do not include physician services, or medical and other health services for which payment may be made under other Medicare provisions (e.g., services of an independent laboratory located on the same site as the ASC, prosthetic devices other than intra-ocular lenses (IOLs), anesthetist’s professional services, and non-implantable durable medical equipment (DME).
ASC services for which payment is included in the ASC payment for a covered surgical procedure include, but are not limited to the following.
Included facility services:
• Nursing, technician, and related services;
• Use of the facility where the surgical procedures are performed;
• Any laboratory testing performed under a CLIA certificate of waiver;
• Drugs and biologicals for which separate payment is not allowed under the hospital outpatient prospective payment system (OPPS); (effective January 1, 2008)
• Medical and surgical supplies not on pass-through status; (effective January 1, 2008)
• Equipment;
• Surgical dressings;
• Implanted prosthetic devices, including intraocular lenses (IOLs), and related accessories and supplies not on pass-through status; (effective January 1, 2008)
• Implanted DME and related accessories and supplies not on pass-through status; (effective January 1, 2008)
• Splints and casts and related devices;
• Radiology services for which separate payment is not allowed under the OPPS, and other diagnostic tests or interpretive services that are integral to a surgical procedure; (effective January 1, 2008)
• Administrative, recordkeeping and housekeeping items and services;
• Materials, including supplies and equipment for the administration and monitoring of anesthesia; and
• Supervision of the services of an anesthetist by the operating surgeon.
Under the revised ASC payment system, the above items and services fall within the scope of ASC facility services, and payment for them is packaged into the ASC payment for the covered surgical procedure. ASCs must incorporate charges for packaged services into the charges reported for the separately payable services with which they are provided. Because contractors pay the lesser of 80 percent of actual charges or the ASC payment rate for the separately payable procedure, and because this comparison is made at the claim line-item level, facilities may not be paid appropriately if they unbundle charges and report those charges for packaged codes as separate line-item charges.
There is a payment adjustment for insertion of an IOL approved as belonging to a class of NTIOLs, for the 5-year period of time established for that class.
The ASC payment rate includes only the specifically identified ASC services, included on the ASC payment list. All other non-ASC services such as physician services, prosthetic devices, etc. may be covered and separately billable under Medicare Part B. The Medicare definition of covered facility services for a covered surgical procedure includes services that would be covered if furnished on an inpatient or outpatient basis in connection with a covered surgical procedure. This includes operating and recovery rooms, patient preparation areas, waiting rooms, and other areas used by the patient or offered for use to patient’s needing surgical procedures. It includes all services and procedures provided in connection with covered surgical procedures furnished by nurses, technical personnel and others involved in patient’s care. These do not include physician services, or medical and other health services for which payment may be made under other Medicare provisions (e.g., services of an independent laboratory located on the same site as the ASC, prosthetic devices other than intra-ocular lenses (IOLs), anesthetist’s professional services, and non-implantable durable medical equipment (DME).
ASC services for which payment is included in the ASC payment for a covered surgical procedure include, but are not limited to the following.
Included facility services:
• Nursing, technician, and related services;
• Use of the facility where the surgical procedures are performed;
• Any laboratory testing performed under a CLIA certificate of waiver;
• Drugs and biologicals for which separate payment is not allowed under the hospital outpatient prospective payment system (OPPS); (effective January 1, 2008)
• Medical and surgical supplies not on pass-through status; (effective January 1, 2008)
• Equipment;
• Surgical dressings;
• Implanted prosthetic devices, including intraocular lenses (IOLs), and related accessories and supplies not on pass-through status; (effective January 1, 2008)
• Implanted DME and related accessories and supplies not on pass-through status; (effective January 1, 2008)
• Splints and casts and related devices;
• Radiology services for which separate payment is not allowed under the OPPS, and other diagnostic tests or interpretive services that are integral to a surgical procedure; (effective January 1, 2008)
• Administrative, recordkeeping and housekeeping items and services;
• Materials, including supplies and equipment for the administration and monitoring of anesthesia; and
• Supervision of the services of an anesthetist by the operating surgeon.
Under the revised ASC payment system, the above items and services fall within the scope of ASC facility services, and payment for them is packaged into the ASC payment for the covered surgical procedure. ASCs must incorporate charges for packaged services into the charges reported for the separately payable services with which they are provided. Because contractors pay the lesser of 80 percent of actual charges or the ASC payment rate for the separately payable procedure, and because this comparison is made at the claim line-item level, facilities may not be paid appropriately if they unbundle charges and report those charges for packaged codes as separate line-item charges.
There is a payment adjustment for insertion of an IOL approved as belonging to a class of NTIOLs, for the 5-year period of time established for that class.
DEFINITION OF AN ASC
An ASC for Medicare purposes is a distinct entity that operates exclusively for the purpose of furnishing outpatient surgical services to patients. The ASC must enter into a participating provider agreement with CMS. An ASC is either independent (i.e., not a part of a provider of services or any other facility), or operated by a hospital (i.e., under the common ownership, licensure or control of a hospital). If an ASC is the latter type, it has the option either of being covered under Medicare as an ASC or continuing to be covered as a hospital-affiliated outpatient surgery department. To be covered as an ASC operated by a hospital, a facility:
• Elects to do so, and continues to be so covered unless CMS determines there is good cause to do otherwise;
• Is a separately identifiable entity, physically, administratively, and financially independent and distinct from other operations of the hospital, with costs for the ASC treated as a non-reimbursable cost center on the hospital’s cost report;
• Meets all the requirements with regard to health and safety, and agrees to the assignment, coverage and payment rules applied to independent ASCs; and
• Is surveyed and approved as complying with the conditions for coverage for ASCs.
If a facility meets the above requirements, it bills NHIC on Form CMS-1500 or the related electronic equivalent and is paid the ASC payment amount.
If a hospital based facility decides not to become a certified ASC it bills the fiscal intermediary (FI) on Form CMS-1450 or the related EDI equivalent and is subject to hospital outpatient billing and payment rules. It is also subject to hospital outpatient certification and participation requirements.
• Elects to do so, and continues to be so covered unless CMS determines there is good cause to do otherwise;
• Is a separately identifiable entity, physically, administratively, and financially independent and distinct from other operations of the hospital, with costs for the ASC treated as a non-reimbursable cost center on the hospital’s cost report;
• Meets all the requirements with regard to health and safety, and agrees to the assignment, coverage and payment rules applied to independent ASCs; and
• Is surveyed and approved as complying with the conditions for coverage for ASCs.
If a facility meets the above requirements, it bills NHIC on Form CMS-1500 or the related electronic equivalent and is paid the ASC payment amount.
If a hospital based facility decides not to become a certified ASC it bills the fiscal intermediary (FI) on Form CMS-1450 or the related EDI equivalent and is subject to hospital outpatient billing and payment rules. It is also subject to hospital outpatient certification and participation requirements.
Ambulatory Surgery Center - Overview
General view about - Ambulatory Surgery Center
Ambulatory surgery centers (ASC) are also known as outpatient surgery centers or same day surgery centers. Medical facilities where surgical procedures not requiring an overnight hospital stay are performed are sometimes called surgicenters. Such surgery is commonly less complicated than that requiring hospitalization. Avoiding hospitalization can result in cost savings to the party responsible for paying for the patient's health care.[1]
An ASC is a health care facility that specializes in providing surgery, including certain pain management and diagnostic (e.g., colonoscopy) services in an outpatient setting. Overall, the services provided can be generally called procedures. In simple terms, ASC-qualified procedures can be considered procedures that are more intensive than those done in the average doctor's office but not so intensive as to require a hospital stay. An ambulatory surgery center and a specialty hospital often provide similar facilities and support similar types of procedures. The specialty hospital may provide the same procedures or slightly more complex ones and the specialty hospital will often allow an overnight stay. ASCs do not routinely provide emergency services to patients who have not been admitted to the ASC for another procedure.
'Procedures' performed in ASCs are broad in scope. In the 1980s and 1990s, many procedures that used to be performed exclusively in hospitals began taking place in ambulatory surgery centers as well. Many knee, shoulder, eye, spine and other surgeries are currently performed in ASCs. In the United States today, more than 50% of Colonoscopy services are performed in ambulatory surgery centers.
The first ASC was established in Phoenix, Arizona in 1970 by two physicians who wanted to provide timely, convenient and comfortable surgical services to patients in their community, avoiding more impersonal venues like regular hospitals.
ASCs rarely have a single owner. Physicians partners who perform surgeries in the center will often own at least some part of the facility. Ownership percentages vary considerably, but most ASCs involve physician owners. Occasionally, an ASC is entirely physician-owned. However, it is most common for development/management companies to own a percentage of the center.
Some large healthcare companies own many types of medical facilities, including ambulatory surgery centers. The largest operator by revenue is Surgical Care Affiliates, which is the former surgery division of HealthSouth Corporation, with 141 centers in 35 states. United Surgical Partners International (USPI) manages 138 centers in the US, Hospital Corporation of America manages 95. There are currently three publicly traded companies in the US who specialize in operating ASCs: NovaMed, AMSURG, and Symbion. There are also many privately held companies in the US who specialize in developing, managing and operating ASCs: Facility Development and Management.
In the United States, more than 22 million surgeries a year are performed in more than 5,000 ASCs. ASCs are in all 50 states and can be found throughout the world. In the US, most ASCs are licensed, certified by Medicare and accredited by one of the major health care accrediting organizations.
Although complications are very rare, ASCs are required by Medicare and the accreditation organizations to have a backup plan for transfer of patients to a hospital if the need arises.
The national nonprofit organizations that represents the interests of ASCs and their patients is Ambulatory Surgery Center Association (ASC Association), which was formed in 2008 when the Federated Ambulatory Surgery Association (FASA) and the American Association of Ambulatory Surgery Centers (AAASC) merged.
Accreditation organizations are separate from the general trade organizations. Accreditation organizations for ASCs provide standards of medical care, record keeping, and auditing for ASCs. Some of the goals of these organizations include continuous improvement of medical care in surgery centers and providing an external organization where the public can get information on many aspects of ASCs. These accreditation organizations require members to receive periodic audits. These audits will come every one to three years, depending on the accreditation organization and the circumstances of the surgery center. In an audit, a team of auditors visits the facility and examines the ASC's medical records, written policies, and compliance with industry standards.
In 1996, California was the first state to require accreditation for all outpatient facilities that administer sedation or general anesthesia. Many other states have followed and require accreditation.
The three main accreditors of ASCs are American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF), Accreditation Association for Ambulatory Health Care (Accreditation Association or AAAHC) and The Joint Commission.
Ambulatory surgery centers (ASC) are also known as outpatient surgery centers or same day surgery centers. Medical facilities where surgical procedures not requiring an overnight hospital stay are performed are sometimes called surgicenters. Such surgery is commonly less complicated than that requiring hospitalization. Avoiding hospitalization can result in cost savings to the party responsible for paying for the patient's health care.[1]
An ASC is a health care facility that specializes in providing surgery, including certain pain management and diagnostic (e.g., colonoscopy) services in an outpatient setting. Overall, the services provided can be generally called procedures. In simple terms, ASC-qualified procedures can be considered procedures that are more intensive than those done in the average doctor's office but not so intensive as to require a hospital stay. An ambulatory surgery center and a specialty hospital often provide similar facilities and support similar types of procedures. The specialty hospital may provide the same procedures or slightly more complex ones and the specialty hospital will often allow an overnight stay. ASCs do not routinely provide emergency services to patients who have not been admitted to the ASC for another procedure.
'Procedures' performed in ASCs are broad in scope. In the 1980s and 1990s, many procedures that used to be performed exclusively in hospitals began taking place in ambulatory surgery centers as well. Many knee, shoulder, eye, spine and other surgeries are currently performed in ASCs. In the United States today, more than 50% of Colonoscopy services are performed in ambulatory surgery centers.
The first ASC was established in Phoenix, Arizona in 1970 by two physicians who wanted to provide timely, convenient and comfortable surgical services to patients in their community, avoiding more impersonal venues like regular hospitals.
ASCs rarely have a single owner. Physicians partners who perform surgeries in the center will often own at least some part of the facility. Ownership percentages vary considerably, but most ASCs involve physician owners. Occasionally, an ASC is entirely physician-owned. However, it is most common for development/management companies to own a percentage of the center.
Some large healthcare companies own many types of medical facilities, including ambulatory surgery centers. The largest operator by revenue is Surgical Care Affiliates, which is the former surgery division of HealthSouth Corporation, with 141 centers in 35 states. United Surgical Partners International (USPI) manages 138 centers in the US, Hospital Corporation of America manages 95. There are currently three publicly traded companies in the US who specialize in operating ASCs: NovaMed, AMSURG, and Symbion. There are also many privately held companies in the US who specialize in developing, managing and operating ASCs: Facility Development and Management.
In the United States, more than 22 million surgeries a year are performed in more than 5,000 ASCs. ASCs are in all 50 states and can be found throughout the world. In the US, most ASCs are licensed, certified by Medicare and accredited by one of the major health care accrediting organizations.
Although complications are very rare, ASCs are required by Medicare and the accreditation organizations to have a backup plan for transfer of patients to a hospital if the need arises.
The national nonprofit organizations that represents the interests of ASCs and their patients is Ambulatory Surgery Center Association (ASC Association), which was formed in 2008 when the Federated Ambulatory Surgery Association (FASA) and the American Association of Ambulatory Surgery Centers (AAASC) merged.
Accreditation organizations are separate from the general trade organizations. Accreditation organizations for ASCs provide standards of medical care, record keeping, and auditing for ASCs. Some of the goals of these organizations include continuous improvement of medical care in surgery centers and providing an external organization where the public can get information on many aspects of ASCs. These accreditation organizations require members to receive periodic audits. These audits will come every one to three years, depending on the accreditation organization and the circumstances of the surgery center. In an audit, a team of auditors visits the facility and examines the ASC's medical records, written policies, and compliance with industry standards.
In 1996, California was the first state to require accreditation for all outpatient facilities that administer sedation or general anesthesia. Many other states have followed and require accreditation.
The three main accreditors of ASCs are American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF), Accreditation Association for Ambulatory Health Care (Accreditation Association or AAAHC) and The Joint Commission.
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