December 15, 2022

ACR Hopeful CMS Corrects Professional/Technical Neuromuscular Code

The Centers for Medicare and Medicaid Services (CMS) omitted the professional component (26) and technical component (TC) modifiers for the neuromuscular ultrasound codes 76881, 76882 and 76883 in the 2023 Medicare Physician Fee Schedule (MPFS) final rule. Physicians are paid by Medicare based on values attributed to codes assigned to services they perform.

For most radiology codes, modifier 26 is used when a physician interprets but does not perform the test, while modifier TC includes the practice expenses (equipment, supplies, clinical staff) and related malpractice expenses associated with the procedure. Without these modifiers, codes 76881, 76882 and 76883 can only be billed globally, indicating that the provider performed both the professional and technical services.

The American College of Radiology® (ACR®) does not agree with only global billing for the neuromuscular ultrasound codes, as CPT® codes 76881 and 76882 have always had -TC and -26 modifiers and radiologists typically bill the -26 separately from the hospitals that would bill the -TC for the use of their facilities. We also have concerns that this change in the final rule will not allow physicians and practices sufficient time to update their systems, and will lead to billing complications and denials beginning Jan. 1.

The ACR, along with other specialties, met with CMS the first week of December to advocate for the professional and technical component modifiers to be reestablished for CPT codes 76881 and 76882. CMS staff listened intently to the points made by the Radiology RUC advisors Andrew Moriarity, MD, and Michael Booker, MD, and CPT advisors Mark Alson, MD, and Eric Rubin, MD, regarding the impacts to radiology.

In response to stakeholder feedback, the ACR is hopeful that CMS will release a correction notice announcing that both professional and technical reimbursement for the neuromuscular codes will continue in 2023.

The ACR will continue to advocate for accurate and appropriate reimbursement for radiology.

For more information, please contact Stephanie Le, ACR Director of Economic Policy.