February 3, 2020
In response to ASHA’s advocacy, the Centers for Medicare & Medicaid Services (CMS) reversed the new National Correct Coding Initiative (CCI) edit that prevented same-day billing of Current Procedural Terminology (CPT ® American Medical Association) codes 92611 (Motion fluoroscopic evaluation of swallowing function by cine or video recording) and 74230 (Radiologic examination, swallowing function, with cineradiography/videoradiography).
In a recent communication, CMS noted that the edit is changed to allow same-day billing of 92611 and 74230, retroactive to January 1, 2020, and will be implemented as soon as technically possible in a future edit update. With the reversal of the CCI edit, speech-language pathologists (SLPs) and radiologists will once again be appropriately reimbursed for each distinctly different portion of their professional collaboration during the videofluoroscopic swallowing study (VFSS).
CMS further clarified that claims for same-day billing of 92611 and 74230 must include a modifier to note that the services are separate and distinct. This means that claims for VFSS should include 92611 first on the claim, as the “column 1” code, followed by 74230 with the modifier -59 (or subcategory modifiers) appended. Additional information on the use of CCI-associated modifiers is available on ASHA’s website.
Once CMS implements the correction, all claims submitted since January 1, 2020, that appropriately included 92611 and 74230 can be reprocessed for payment of 74230, with the addition of the modifier to 74230 as the “column 2” code.
ASHA appreciates the reversal by CMS that reaffirms the important collaboration of SLPs and radiologists during the VFSS.
Update (February 5, 2020): ASHA received official confirmation regarding the reversal from CMS and the NCCI contractor, as follows.
“CMS will change the Practitioner (PRA) and Outpatient Hospital (OPH) Modifier indicator for the following January 1, 2020 PTP edit:
|Column 1||Column 2||PRA Modifier Indicator||OPH Modifier Indicator|
These changes will be retroactive to January 1, 2020 and will be implemented in a future edit update.”
As noted above, the modifier indicator of “1” means that a CCI-associated modifier is appropriate to indicate separate and distinct services when both codes are submitted on the claim.
CMS also indicated that the updated edit will be posted on the Medicare and Medicaid websites. However, the update has not been posted as of Wednesday, February 5, 2020.
CMS provided no further clarification regarding a timeline or how to handle claims submissions prior to the implementation of the corrected edit. Providers may consider submitting claims based on the current edit and resubmitting for payment once the corrected edit is implemented.
The NCCI (or more commonly, CCI) is an automated edit system to control specific procedure code pairs that can or cannot be reported on the same day. CMS developed the system for use in all Medicare Part B (outpatient) and Medicaid claims. See CCI Edits for Speech-Language Pathology Services for additional information on same-day billing restrictions and related modifiers.