Newly Announced NCCI Edits Affect Society Members The Centers of Medicare and Medicaid Services (CMS) recently posted National Correct Coding Initiative (NCCI) edits (Version 16.0 effective January 1, 2010) to its website. These edits will bundle CPT codes for catheter ablation (93650-93652) with codes for recording, pacing and electrophysiology study (93600-93603, 93610-93612, 93618-93623) and change the modifier indicator status from “1” to “0” on existing edits.
This issue has been immediately brought to the attention of CMS, which owns NCCI and makes all decisions about its content, to retroactively remove this restriction.
Effective January 1, the following code pairs are now assigned a modifier indicator of “0” to signify that NCCI-associated modifiers cannot be used to override the edit. A modifier indicator of “0” also establishes that you should only report the service in Column One. With these code pair edits in place, currently there is no way to receive payment for recording, pacing and electrophysiology study when performed on the same date of service as an intracardiac catheter ablation procedure.
Cardiac SVT ablation (93651) now includes these components (“0” modifier indicator):
Cardiac AV ablation (93650) now includes these components (“0” modifier indicator):
- Recording: 93602, 93603
- Pacing: 93610, 93612, 93618, 93623
- EP study: 93619, 93620-93622
Cardiac VT ablation (93652) includes these components (“0” modifier indicator):
- Bundle of His: 93600
- Recording: 93602, 93603
- Pacing: 93610, 93612, 93618
These edits were originally proposed for implementation in NCCI Version 15.3 effective October 1, 2009. On April 16, 2009, the Heart Rhythm Society received a letter from NCCI regarding CMS’ proposal to bundle the ablation family of CPT codes with recording, pacing and electrophysiology study and to change the modifier indicator status on existing edits. The Society successfully opposed the edits in a letter to CMS dated June 18, 2009, expressing concern about the impact the change would have on medical decision making and the potential threat to patient access to critical services for the treatment of cardiac arrhythmias. [Read Society comment letter, PDF, 149K]. The NCCI edits are also in direct contradiction to the coding conventions and instructions in the CPT guidelines.
After reviewing the Society’s comments, CMS withdrew the proposal in its entirety*.
Despite our efforts to prevent the edits from being implemented, they were included in Version 16.0 unbeknownst to the Society or American College of Cardiology. The Heart Rhythm Society will vigorously challenge NCCI and CMS on this issue and will continue to advocate our position on appropriate coding for ablation procedures.
* The Heart Rhythm Society received a letter dated June 24, 2009 from Niles R. Rosen, MD, Medical Director of NCCI, stating "CMS will not implement the new edits or modifications of active edits described in my April 16, 2009 letter." [Read full letter, PDF, 132K]
