Compliance Question of the Week – General

Has CMS issued the inpatient rules for 2019 yet?

I know that providers are supposed to check the PTP edits before submitting Medicare claims, but what about the mutually exclusive edits?

When can providers accept the new Medicare beneficiary cards?

What is the new Medicare legislation called IMPACT about?

How does CMS define the term “separate procedure” that is used in CPT® code descriptions?

Is Medicare’s initial preventive physical exam (IPPE) the same as a beneficiary’s yearly physical?

Does Medicare offer guidance related to when unspecified diagnosis codes are appropriate?

Where can I find Medicare’s electronic clinical quality measures for next year?

I believe the answer you gave to the 5-14 general coding question is inaccurate. The question was about the correct coding of DM with a URI and CKD. Your answer gave the code for a UTI not URI.

When DM is an affecting condition for URI and the patient also has CKD, which is not treated or affecting at this encounter, do I use the combination code for hypertensive CKD or just the DM code?

I read the answer to your March 19 question, and I don’t believe the response from MedLearn completely answers the question posed by the writer. Specifically:

• The question did not mention anything about a patient being seen in different hospital departments.
• The response refers to the NCCI Policy Manual for Medicare Services, chapter XI, section B, item 4, indicating that the following guideline can be found there: “When the PICC is inserted/placed by the same department (cost center) then the IV Infusion/injection is considered a component of the procedure and not separately billable.” However, I do not see any reference in the NCCI manual guidance about the same department (cost center). For this chapter, go to file:///C:/Users/Tillie/AppData/Local/Temp/Temp1_NCCI-Policy-Manual-2018.zip/CHAP11-CPTcodes90000-99999_final%20103117.pdf.
My interpretation of the NCCI manual guidance, item 4 is as follows: It states that placement of peripheral vascular access devices is integral to IV infusion and injections and not separately reportable (e.g., 36000—introduction of needle/catheter into vein), 36410—venipuncture). This guidance is also documented in the CPT manual under the Vascular Injection Procedures section, which is referring to intravenous injection procedures into veins and arteries or catheters (e.g., peripheral IV access.)

However, per the NCCI guidance, if it is central venous access (e.g., CPT 36568, 36569), which is not routinely necessary to perform infusions/injections, this service MAY be reported separately. Central venous access procedures are different than vascular injection procedures.

So, if a PICC meets the description of a peripherally inserted central venous catheter (per the CPT manual) “to qualify as a central venous access catheter or device, the tip of the catheter/device must terminate in the subclavian, brachiocephalic (innominate) or iliac veins, the superior or inferior vena cava , or the right atrium” then when CPT codes for central venous access catheter procedures are reported with a CPT code for the IV infusion/injection administered on the same day, per the CPT manual and NCCI manual guidance and instruction it is appropriate to report it with the -59 or XU modifier regardless of the same department or revenue center.

I would appreciate your review of the initial question and my comments and any additional explanation or information you could provide on this issue.

When will CMS issue the new Medicare cards?