Coding Updates for Dosimetry Services

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1 Coding Updates for Dosimetry Services Presented at AAMD Annual Meeting Monday, June 22, 2015 Grande Lakes Hotel Orlando, FL

2 Contact Information Revenue Cycle Inc W. Braker Lane Bldg. F, Suite 200 Austin, Texas (512)

3 Presenters Tamara Syverson, BSRT(T) Director Provider Consulting Scott Plemmons, RT(R)(T) Consultant

4 Disclaimer This presentation was prepared as a tool to assist attendees in learning about documentation, charge capture and billing processes. It is not intended to affect clinical treatment patterns. While reasonable efforts have been made to assure the accuracy of the information within these pages, the responsibility for correct documentation and correct submission of claims and response to remittance advice lies with the provider of the services. The material provided is for informational purposes only. Efforts have been made to ensure the information within this document was accurate on the date of presentation. Reimbursement policies vary from insurer to insurer and the policies of the same payor may vary within different U.S. regions. All policies should be verified to ensure compliance. CPT codes, descriptions and other data are copyright 2014 American Medical Association (or such other date of publication of CPT ). All Rights Reserved. CPT is a registered trademark of the American Medical Association. Code descriptions and billing scenarios are references from the AMA, CMS local and national coverage determinations (LCD/NCD), the ASTRO/ACR Guide to Radiation Oncology Coding, the ACRO Practice Management Guide and common practice standards nationwide.

5 Objectives Educate Attendees on Changes in Coding for Dosimetry Services Discuss the Differences Between Hospital and Freestanding Provide Information on Work Flow Processes Discuss Recommendations for Documentation

6 Our Policy Consistent with Medicare Guidelines Local Coverage Determinations Medicare Manuals CCI/OCE Edits CPT Definitions & Advice for AMA Published OIG Compliance Standards Professional Society Publications In Absence of Published Guidelines Revenue Cycle Inc. experience and observations nationally

7 Rules & Regulations Authoritative Guidance: Federal Register Centers for Medicare & Medicaid Services (CMS) National Coverage Determinations (NCD) Local Coverage Determinations (LCD) Medicare Manuals Coding Edits: NCCI, OCE, MUE American Medical Association (AMA) Commercial Payor Policies

8 Coding Changes Overview Freestanding departments CT guidance included in the initial simulation process New CPT codes for isodose plans and brachytherapy planning Multiple new G codes for treatment delivery and IGRT Hospitals New CPT codes for planning, treatment delivery and IGRT Simulation

9 Simulation Freestanding Centers The Practice Expense (PE) was updated to include the cost the CT and is no longer separately billable Hospitals The CT continues to be packaged and is separately billable but is reimbursed at $0 for Medicare

10 BUT WAIT!!

11 New Changes With Simulation Billing Per new ASTRO coding update 6/12/15 Simulation followed by 2 or 3D course Simulation and CT (hospital only) remains billable When the course is to be IMRT.. The simulation is now bundled for physicians and freestanding and not billable Ongoing OIG reviews in the hospital setting Treatment devices are still billable per payor guidelines Included on the OIG Fiscal Year 2015 Work Plan Mid-Year Update Published May 2015

12 Radiation Therapy Code Revisions Not all of the newly introduced radiation therapy CPT codes for 2015 were adopted for MPFS use in 2015 The timing of the release of new codes by the AMA and RUC is creating an issue for CMS Postponement until 2016 will allow for proper valuation and review of impact on stakeholders Deleted 2014 codes for treatment delivery, planning and IGRT will still be deleted; however, new Gcodes will be used for some of the new replacement and/or revised codes for 2015

13 Coding For Isodose Planning Planning Codes Teletherapy isodose plan; simple (1 or 2 unmodified ports directed to a single area of interest), includes basic dosimetry calculation(s) Teletherapy isodose plan; complex (multiple treatment areas, tangential ports, the use of wedges, blocking, rotational beam, or special beam considerations), includes basic dosimetry calculation(s) 77321* Special teletherapy port plan, particles, hemibody, total body i.e., protons, neutrons and electrons *Do not bill in conjunction with per AMA

14 2015 Isodose Planning Changes Summary 2014 isodose planning codes deleted 2 new codes created to replace simple and complex Includes calculations Codes to be used for HOPPS and MPFS 2015 HOPPS 2014 CPT 2015 MPFS No code No code

15 Brachytherapy Isodose Plan Codes Brachytherapy isodose plan; simple (calculation[s] made from 1 to 4 sources, or remote afterloading brachytherapy, 1 channel), includes basic dosimetry calculation(s) Intermediate (calculation[s] made from 5 to 10 sources, or remote afterloading brachytherapy, 2-12 channels), includes basic dosimetry calculation(s) Complex (calculation[s] made from over 10 sources, or remote afterloading brachytherapy, over 12 channels), includes basic dosimetry calculation(s)

16 2015 Brachytherapy Isodose Planning Changes Summary 2014 isodose planning codes deleted 3 new codes created Include calculations Codes to be used for HOPPS and MPFS 2014 CPT 2015 HOPPS 2015 MPFS

17 Basic Dosimetry Calculation Basic radiation dosimetry calculation, central axis depth dose calculation, TDF, NSD, gap calculation, off axis factor, tissue inhomogeneity factors, calculation of non-ionizing radiation surface and depth dose, as required during course of treatment, only when prescribed by the treating physician Not billable with the brachytherapy isodose plan Decay factor calculations on subsequent dates may be billed Noridian Brachytherapy LCD states: Requires supporting documentation, including physician signature

18 IGRT Image Guided Radiation Therapy (IGRT) utilizes various imaging technologies to account for changes in the position of the intended target before or during treatment delivery. Hospital Guidance for localization of target volume for delivery of radiation treatment delivery, includes intrafraction tracking, when performed Physicians and Freestanding Cancer Centers G6001 (76950) - Ultrasonic guidance for placement of radiation therapy fields G6002 (77421) - Stereoscopic x-ray guidance for localization of target volume for the delivery of radiation therapy. G6017 (0197T) - Intra-fraction localization and tracking of target or patient motion during delivery of radiation therapy (e.g. 3D positional tracking, gating, 3D surface tracking), each fraction of treatment Computed tomography guidance for placement of radiation fields

19 2015 IGRT Changes Hospital Outpatient: 76950, and 0197T deleted January 1, no longer associated with IGRT Only billable for treatment planning CT TC separately billable for 3D delivery when supported TC bundled with IMRT delivery codes, not separately billable Physician & Freestanding: MPFS not recognizing AMA IGRT code changes in 2016 G-codes created for 76950, and 0197T G6001, G6002 & G used for CBCT (physicians and FSCs)

20 Image Guidance CY2014 Codes AMA New Codes Hospital Use CMS Final Codes CY2015 Physician & FSC Use CY2016 Codes HOPPS & MPFS Use G G T G * *continue to use *77014 was not deleted, per AMA it is no longer billable for IGRT, this will only apply to hospitals in Hospitals will continue to report TC for the treatment planning CT, but will no longer report for the CBCT. Physicians and FSCs will report for CBCT at time of treatment for CMS patients since they are not following AMA guidelines for imaging in 2015.

21 Treatment Delivery Changes 77403, 77404, 77406, 77408, 77409, 77411, 77413, 77414, 77416, and 0073T deleted New CPT codes for hospital outpatient locations G-codes created for use in freestanding facilities

22 HOPPS Treatment Delivery Code Descriptor Radiation treatment delivery, superficial and/or ortho voltage, per day Radiation treatment delivery, > 1 MeV; simple Radiation treatment delivery, > 1 MeV; intermediate Radiation treatment delivery, > 1 MeV; complex Simple: All of the following criteria are met (and none of the complex or intermediate criteria are met): single treatment area; one or two ports; and two or fewer simple blocks Intermediate: Any of the following criteria are met (and none of the complex criteria are met): two separate treatment areas; three or more ports on a single treatment area; or three or more simple blocks Complex: Any of the following criteria are met: three or more separate treatment areas; custom blocking; tangential ports; wedges; rotational beam; field-in-field or other tissue compensation that does not meet IMRT guidelines; or electron beam

23 CPT Update CPT Manual: Energies below the megavoltage range may be used in the treatment of skin lesions. Superficial radiation energies (up to 200kV) may be generate by a variety of technologies and should not be reported with megavoltage (77402, 77407, 77412) for surface application. Do not report clinical treatment planning (77261, 77262, 77263), treatment devices (77332, 77333, 77334), isodose planning (77306, 77307, 77316, 77317, 77318), physics consultation (77336), or radiation treatment management (77427, 77431, 77432, 77435, 77469, 77470, 77499) with When reporting alone, physician evaluation and management, when performed, may be reported with the appropriate E/M codes.

24 HOPPS Treatment Delivery (IMRT) Code Descriptor Intensity modulated radiation treatment delivery (IMRT), includes guidance and tracking, when performed; simple Intensity modulated radiation treatment delivery (IMRT), includes guidance and tracking, when performed; complex Simple: Any of the following: prostate, breast, and all sites using physical compensator-based IMRT Complex: Includes all other sites if not using physical compensatorbased IMRT

25 2015 IMRT Treatment Delivery 2014 codes deleted for HOPPS Two new codes created Simple Complex G-codes created for MPFS IGRT included for HOPPS IGRT possible for MPFS 2015 HOPPS 2014 CPT 2015 MPFS simple complex G simple 0073T G6016

26 Freestanding Treatment Delivery Code Descriptor G6003 G6004 G6005 G6006 G6007 G6008 G6009 G6010 G6011 G6012 G6013 G6014 G6015 G6016 Radiation treatment delivery, single treatment area, single port or parallel opposed ports, simple blocks or no blocks; up to 5 MeV Radiation treatment delivery, single treatment area, single port or parallel opposed ports, simple blocks or no blocks; 6-10 MeV Radiation treatment delivery, single treatment area, single port or parallel opposed ports, simple blocks or no blocks; MeV Radiation treatment delivery, single treatment area, single port or parallel opposed ports, simple blocks or no blocks; 20 MeV or greater Radiation treatment delivery, 2 separate treatment areas, 3 or more ports on a single treatment area, use of multiple blocks; up to 5 MeV Radiation treatment delivery, 2 separate treatment areas, 3 or more ports on a single treatment area, use of multiple blocks; 6-10 MeV Radiation treatment delivery, 2 separate treatment areas, 3 or more ports on a single treatment area, use of multiple blocks; MeV Radiation treatment delivery, 2 separate treatment areas, 3 or more ports on a single treatment area, use of multiple blocks; 20 MeV or greater Radiation treatment delivery, 3 or more separate treatment areas, custom blocking, tangential ports, wedges, rotational beam, compensators, electron beam; up to 5 MeV Radiation treatment delivery, 3 or more separate treatment areas, custom blocking, tangential ports, wedges, rotational beam, compensators, electron beam; 6-10 MeV Radiation treatment delivery, 3 or more separate treatment areas, custom blocking, tangential ports, wedges, rotational beam, compensators, electron beam; MeV Radiation treatment delivery, 3 or more separate treatment areas, custom blocking, tangential ports, wedges, rotational beam, compensators, electron beam; 20 MeV or greater Intensity modulated treatment delivery, single or multiple fields/arcs, via narrow spatially and temporally modulated beams, binary, dynamic MLC, per treatment session Compensator-based beam modulation treatment delivery of inverse planned treatment using 3 or more high resolution (milled or cast) compensator Copyright 2015 RCI convergent All Rights Reserved. beam Do modulated Not Duplicate. fields, per treatment session

27 2015 Conventional Treatment Delivery 2015 HOPPS 2014 CPT 2015 MPFS G G G G G6007 All but 3 deleted Remaining 3 adjusted to remove energy dependence G-codes created for MPFS G G G G G G G6014

28 C-APC for SRS HOPPS Only C-APC for GammaKnife SRS, only the treatment is reimbursed. All ancillary charges are reported with cost, but not reimbursed separately Includes simulation, planning, calculations, devices, physics and imaging codes Physicians (Rad Onc and Neuro) will continue to report services on CMS1500 and reimbursed separately

29 C-APC Course Info HOPPS Only Category Pre-Sim CPT 2015 APC 2015 SI CPT Description CO-60 SRS - National Average 2014 National APC Rate 2015 National APC Rate Quantity 2015 Quantity Billed due to Packaging 2014 Total APC Pmt 2015 Total APC Pmt G Q3 Hospital outpt clinic visit $ $ $ $ S Special radiation treatment $ $ $ $ N Ct scan for therapy guide $ - $ $ - $ - Simulation S Set radiation therapy field $ $ $ $ S Radiation treatment aid(s) $ $ $ $ S Radiation physics consult $ $ $ $ - Planning S 3-d radiotherapy plan $ 1, $ 1, $ 1, $ S Radiation therapy dose plan $ $ $ $ S Radiation treatment aid(s) $ $ $ $ - Treatment 77371* 0067 J1 Srs multisource $ 3, $ 9, $ 3, $ 9, S Radiation physics consult $ $ $ $ - $ 6, $ 9, Total for Medicare Only $ 2, Course of Therapy Variance % Change 41.77% The example course illustrated is a Stereotactic Radiosurgery course. It assumes a complex initial simulation to one area which will require complex blocking. The example course assumes 5 portals utilizing 2 unique blocking patterns. The total number of fractions is 1. It is further noted, due to CY2015 proposed packaging all ancillary codes are reported on the claim forms, the payment is only made for the C-APC Associated reimbursement only appears in the CY in which it applies. *For 2015 SRS all services performed in order to deliver the single fraction of SRS are packaged into the reimbursement for the treatment delivery. All ancillary codes are reported with cost listed, but are not separately reimbursed. The quantities for 2015 reflect the cost reporting quantities with the only reimbursement for

30 Surgical APCs Code (Insertion of uterine tandem and/or vaginal ovoids for clinical brachytherapy) moved once again from APC 0193 to 0192 CY2014 payment APC 0193= $1, CY2015 APC payment 0192= $ a 63% reduction! IORT codes & finalized move from APC 0065 to C-APC 0648 (Level IV Breast and Skin Surgery) APC 0065 deleted, leaving MRgFUS codes and MEG codes and being moved to APC 0446

31 What s Coming for 2016??? Calculations appear to be bundled with 3D planning New treatment delivery codes for electronic brachytherapy Handling and loading (77790) for LDR brachytherapy Transition of the 2015 G code to current CPT codes Be sure to watch for Proposed Rule updates to be released soon!!

32 Questions?

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