Coding & Billing

Share:

Avoiding Denials of Questionable Covered Services


Lolita M. Jones, RHIA, CCS You can't automatically assume that a procedure is eligible for reimbursement just because it's on the Centers for Medicare and Medicaid Services' (CMS) list of covered ASC procedures. CMS designates some procedures as Questionable Covered Services (QCS), which means that they are only covered when medically necessary. Examples include certain types of blepharoplasty, rhytidectomy, lipectomy, mammaplasty and abortion. Here are three ways to make sure you don't end up with unpleasant surprises when the time comes to collect reimbursement for these cases.

Lolita M. Jones, RHIA, CCS 1. Research procedure coverage policies
CMS's Medicare coverage database at writeOutLink("www.cms.hhs.gov/coverage",1) contains three coverage documents that will guide you to the conditions under which QCSs will be approved for reimbursement: national coverage decisions (NCDs), national coverage analyses (NCAs) and local medical review policies (LMRPs).

The database is a work in progress. Medicare contractors still contribute previously unlisted LMRPs to the database; it will be several months before this phase of the project is done. Until the transition is complete, a full list of LMRPs is available at www.lmrp.net. This portion of the database will be updated on a monthly basis. The last, up-to-date version of a contractor's LMRPs will be available on each contractor's Web site.

New Questionable Covered Services

Here's a sample of the the new ASC List procedure codes (which take effect July 1) that CMS has designated as Questionable Covered Services (QCS).

CPT

Description

15775

Punch graft for hair transplant; 1 to 15 punch grafts

15776

Punch graft for hair transplant; more than 15 punch grafts

15820

Blepharoplasty, lower eyelid;

15821

Blepharoplasty, lower eyelid; with extensive herniated fat pad

15822

Blepharoplasty, upper eyelid;

15823

Blepharoplasty, upper eyelid; with excessive skin weighting down lid

15824

Rhytidectomy; forehead

15825

Rhytidectomy; neck with platysmal tightening (platysmal flap, P-flap)

15826

Rhytidectomy; glabellar frown lines

15828

Rhytidectomy; cheek, chin, and neck

15829

Rhytidectomy; superficial musculoaponeurotic system (SMAS) flap

15831

Excision, excessive skin and subcutaneous tissue (including lipectomy) abdomen (abdominoplasty)

15832

Excision, excessive skin and subcutaneous tissue (including lipectomy) thigh

15833

Excision, excessive skin and subcutaneous tissue (including lipectomy) leg

15834

Excision, excessive skin and subcutaneous tissue (including lipectomy) hip

15876

Excision, excessive skin and subcutaneous tissue (including lipectomy) buttock

15835

Suction assisted lipectomy; head and neck

15877

Suction assisted lipectomy; trunk

15878

Suction assisted lipectomy; upper extremity

15879

Suction assisted lipectomy; lower extremity

19316

Mastopexy

19324

Mammaplasty, augmentation; without prosthetic implant

19325

Mammaplasty, augmentation; with prosthetic implant

19364

Breast reconstruction with free flap

59840

Induced abortion, by dilation and curettage

59841

Induced abortion, by dilation and evacuation

69300

Otoplasty, protruding ear, with or without size reduction

Medicare contractors (fiscal intermediaries [FIs] and carriers) are also uploading coverage and coding articles to the database. Medicare contractors may make independent coverage decisions if an NCD or the Medicare Manual does not specifically address the item or service.

2. Mind your Ps and Q(CS)s
Medicare carriers process outpatient claims against national coverage policy edits from CMS. "Questionable Covered Service" is an edit that flags provider claims with CPT codes that describe procedures that are only covered by the Medicare program under certain medical circumstances. The carrier may also have LMRPs for some codes they consider a QCS. Medicare won't cover breast reconstruction for free flap (CPT code 19364) when performed for cosmetic reasons, but it will if performed as a follow-up to mastectomy.

3. Bill proactively.
Medicare carriers routinely suspend claims containing a QCS CPT code and request a copy of the operative report/ procedure note. If the documentation supports the medical necessity of the procedure, the claim will be paid. Otherwise, expect a denial. Two simple billing practices can speed up reimbursement turnaround and reduce the risk of the Medicare carrier denying your QCS claim.

First, submit these claims manually and attach a copy of the operative/procedure note. This lets the carrier review the claim immediately instead of suspending it and holding it up while you mail a copy of the operative note.

Secondly, send any additional supporting medical documentation along with the claim. For example, for eyelid reconstructive surgery, send photographs of the patient's eyelids.

Coverage Policies for QCSs

Many Medicare carriers have established coverage policies for procedures they've classified as Questionable Covered Services. For example, HGS Administrators, the Medicare carrier for Pennsylvania, will cover blepharoplasty procedures when performed as functional/reconstructive surgery to correct:

  • visual impairment due to dermatochalasis or blepharochalasis,
  • symptomatic redundant skin that is resting on upper lashes,
  • chronic, symptomatic dermatitis of pretarsal skin caused by redundant upper lid skin, or
  • prosthesis difficulties in an ophthalmic socket.

HGS has similar policies in place for brow ptosis or blepharoptosis repairs.

If you give the carrier all the tools it needs to approve payment, you'll get paid quickly and in full for these "questionable" procedures.

Related Articles

Wired for Success

In her 24 years as a nurse at Penn Medicine, Connie Croce has seen the evolution from open to laparoscopic to robotic surgery....

To Optimize OR Design, Put People First

Through my decades of researching, testing and helping implement healthcare design solutions, I’ve learned an important lesson: A human-centered and evidence-based...