January 14, 2020
Effective January 1, 2020, the Centers for Medicare & Medicaid Services (CMS) implemented a new National Correct Coding Initiative (CCI) edit that prevents same-day billing of Current Procedural Terminology (CPT ® American Medical Association) codes 74230 (Radiologic examination, swallowing function, with cineradiography/videoradiography) and 92611 (Motion fluoroscopic evaluation of swallowing function by cine or video recording).
Speech-language pathologists (SLPs) typically collaborate with radiologists to perform the videofluoroscopic swallowing study (VFSS), also called the modified barium swallowing (MBS) study. CPT codes 74230 and 92611 describe the work required to identify the medical diagnosis by the radiologist (74230) and to evaluate swallowing function by the SLP (92611). With the new CCI edit in place, SLPs and radiologists will not be appropriately reimbursed for each distinctly different portion of their professional collaboration during the VFSS.
ASHA is engaging with CMS and the contractor that manages the NCCI program to resolve this issue. In the meantime, ASHA recommends providers continue to submit same-day claims for 92611 and 74230. Because the new CCI edit lists 92611 as the “column 1” code, it should be placed first on the claim, followed by 74230. This means that 92611 should be processed for payment, but 74230 will be denied. If CMS reverses the CCI edit, all claims submitted since January 1, 2020, can be reprocessed for payment of 74230.
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.