An unresolved error in some HCPCS code manuals has prolonged confusion over proper reporting and payment of L8680 Implantable neurostimulator electrode, each. To ensure complete reimbursement, review claims going back to Jan. 1, 2010 and keep watching claims for at least the rest of 2011.
Wrong descriptor in print
A neurostimulator assembly consists of a pulse generator or receiver (a power source) and 1 or more electrode arrays, also called leads. Each array typically includes multiple electrodes. In 2009, 1 unit of L8680 was billed for each electrode, or contact point. For example, a single array with 4 electrodes would be reported as L8680 x 4.
In November 2009, CMS released the 2010 Alpha-Numeric HCPCS file with a revised long descriptor for L8680, which specified Implantable neurostimulator electrode (with any number of contact points), each. The phrase "with any number of contact points" now meant that an array with 4 electrodes would be reported as L8680 x 1, rather than as L8680 x 4, as had been the case.
A short time later, in response to physician specialty organization and medical device manufacturer inquiries, CMS announced that effective Jan. 1, 2010, the long descriptor for L8680 would revert to Implantable neurostimulator electrode, each. In other words, the descriptor wouldn't change from 2009, and the code would be applied just as it had been. For example, 2 arrays, each with 4 electrodes, would be reported as L8680 x 8 (not L8680 x 2).
Unfortunately, the 2010 HCPCS Correction file (www.cms.gov/HCPCSReleaseCodeSets/ANHCPCS/list.asp), which properly listed the descriptor for L8680 as Implantable neurostimulator electrode, each, was released after many 2010 HCPCS codebooks had gone to press. More unfortunate still, several versions of the HCPCS manual repeated the error for 2011, and continue to include the retracted "any number of contact points" descriptor.
Review your EOBs for L8680
While the incorrect descriptor remains in print, providers and payors alike risk assigning L8680 in error. Correct coding and reimbursement require that you report a single unit of L8680 for each implanted electrode (contact point). Review your EOBs for L8680 claims going back to Jan. 1, 2010, to be sure those claims were processed and paid correctly, and apply the code appropriately going forward.
Hospitals and ASCs may use L8680 to report outpatient services to non-Medicare payors (verify individual payor policies). Medicare doesn't allow separate payment for implanted neurostimulator devices in the ASC because the surgical procedure codes are considered to be device-intensive procedures, and the implants are included in reimbursement for the surgical procedure. Outpatient hospitals must use C-codes when reporting devices to Medicare. In a hospital outpatient setting, report a neurostimulator lead using C1778 Lead, neurostimulator (implantable). HCPCS C1778 is reimbursed per lead (array), rather than by electrode. For example, a single array with 4 contact points would be reported as C1778 x 1.
OPPS Offers Retroactive Payment Corrections
You might be eligible for retroactive payment corrections. CMS Transmittal 2174 (www.cms.gov/transmittals/downloads/R2174CP.pdf) announced updates for the Hospital Outpatient Prospective Payment System (OPPS), effective April 1. The update includes a significant number of retroactive payment corrections, which could mean recovered reimbursement for outpatient services. Payment corrections apply for the following codes for claims filed between Oct. 1 and Dec. 31, 2010:
J0833 Cosyntropin injection NOS
A payment correction also applies to Q4118 Matristem micromatrix for claims filed between Jan. 1 and March 31, 2011.
Code Q4419 Matristem wound matrix, per square centimeter has been granted a "K" status indicator retroactively, thereby allowing separate payment for all claims on or after Jan. 1. Previously, the code had been assigned an "E" status indicator, meaning it was not paid for outpatient claims. As well, G0010 Administration of hepatitis B vaccine has been granted an "S" status indicator (significant procedure, not discounted when multiple) retroactive to Jan. 1, 2011.
For all of the codes listed above, review past claims to determine if your facility is due retroactive payment adjustments.
Additional changes in the OPPS quarterly update include pass-through status for 3 new drugs:
C9280 Injection, eribulin mesylate, 1mg (APC 9280)
Also included is a new code for use in the hospital outpatient setting, beginning April 1. HCPCS Q2040 Injection, incobotulinumtoxin A, 1 Unit (APC 9278) replaces C9278 to report Xeomin. A new service, C9729 Percutaneous laminotomy/laminectomy (intralaminar approach) for decompression of neural elements, (with ligamentous resection, discectomy, facetectomy and/or foraminotomy, when performed) any method under indirect image guidance, with the use of an endoscope when performed, single or multiple levels, unilateral or bilateral; lumbar (APC 0208) has been assigned for payment under OPPS. HCPCS Q1003 New technology intraocular lens category 3 is packaged under OPPS, and will be deleted beginning April 1.
Go to www.cms.hhs.gov/mlnmattersarticles for more on the April 1 OPPS update.
G. John Verhovshek, MA, CPC