January 08, 2016

CMS Implements Controversial Radiotherapy Code Edits

The Centers for Medicare & Medicaid Services (CMS) implemented National Correct Coding Initiative (NCCI) edits on January 1, 2016, for the code pair 77295 (three-dimensional radiotherapy planning, including dose-volume histograms) and 77300 (Basic radiation dosimetry calculation), despite long-standing opposition by the American College of Radiology (ACR) and American Society of Radiation Oncology (ASTRO).

In a June 27, 2014 letter to the NCCI medical director, the ACR and ASTRO strongly disagreed with the placement of a modifier indicator of “0” (no modifier allowed to be used to bypass the edit) for the reporting of 77295 for 3D radiotherapy plans including dose-volume histograms, in conjunction with 77300 for a basic radiation dosimetry calculation.

The specialty societies argued that the work of CPT code 77300 was bundled into isodose planning codes 77305, 77326, 77327 and 77328, but 77295 was specifically excluded from the April 2014 bundling request by the Joint CPT/RUC Workgroup and Relatively Assessment Workgroup. In addition, the revaluation of CPT code 77295 in February 2013 did not account for the value of work described by CPT 77300.