Anesthesia & Pain Management Compliance Auditors

 

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Wednesday, February 22, 2012  
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ACE Newsletter: The Compliance Corner

We hope you find our newsletter to be an easy way to stay abreast of the many changes affecting your profession and specialty.

JANUARY 2011 Newsletter:
 

Welcome to 2011.  I was recently reminded of a quote from the book, A Compass to Fulfillment, "Our lives take on their true meanings when we do our best at the ordinary things in life..."  To me documentation and compliance are the ordinary tasks that must be done to show excellence and achieve fulfillment.  Compliance is not glamorous, it is not fun but it is a necessary task in today's business world of healthcare.

 

To start the year off, healthcare attorney Vicki Myckowiak has written an article reminding us of the requirements of your compliance program.  Please read article at the link provided below and then review your program documents making sure that you have policies updating the changes last year in the rules regarding the hospital's condition of participation on pre and post anesthesia visits.

 

Another important duty that is good to do each January is to check the OIG sanctions and the CMS exclusions lists.  The two links below will assist you in getting this task completed.  Remember to check all employees and business partners that you work with.  The web sites are as follows:  https://oig.hhsc.state.tx.us/exclusions/search.aspx and http://exclusions.oig.hhs.gov

 

In this issue:

Compliance Programs:  An Overview by Vicki Myckowiak, Esq. (Click here for article)

Preparing for 5010 Errata - Deadline January 2012 (Click here for alert) 

 

Ask ACE

In this continuing series, ACE Auditors answer some of the common questions we receive related to anesthesia and pain mangement billing, coding, and practive management

Question: What is the appropriate ASA code to use when billing Temporary Prostate Brachytherapy.  Our question is if the use of the 77777/77778 for the interstitial radiation source application would qualify under this comment (Report code 01922 when the medical imaging is the primary service, an integral component of the therapeutic service not otherwise reportable or when it increases the complexity of the anesthesia care.)  to be billed as the primary procedure and therefore allow us to bill for the higher base of 7’: 

Answer:    Normally the primary reason for anesthesia is the placement of needles/catheters (55875) or placement of interstitial device (55876).  Code 55876 is for radiation therapy guidance and according to CPT it would not be associated with 77777 or 77778; see notation under code.  Therefore you would only use the anesthesia cross codes associated with 55876.  CPT 55876 is only used when a non-radioactive procedure is performed; which is placement of the fiducial markers or dosimeter. These are usually placed on the left and right of the prostate (2 markers) or they can be placed in a triangle formation surrounding the prostate (3 markers).

If the provider calls it Brachytherapy you should code 55875 which is the radioisotope or interstitial radioelement application. You would never use 55876 if the procedure is stated as either Brachytherapy or seed implant. Under code 55875 it refers the coder to 77776-77787 if interstitial radioelement application is used.   However these codes are not the integral component of the service provided.  According to discussion with a radiology coding specialist the surgeon(s) reports the following codes when doing the brachytherapy procedure:

  • 55875
  • 76965
  • 76873

Again you would only use the anesthesia cross codes associated with 55875. 

Question submitted by ACE Consultant, Debbie Farmer, CPC, ACS-AN

To submit a question to one of our consultants click here.

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