The Centers for Medicare and Medicaid (CMS) decided to implement a National Correct Coding Initiative (NCCI) edit for the code pair 77295/773000 effective January 1, 2016. In a June 27, 2014 letter to the NCCI medical director, the ACR and ASTRO strongly disagreed with the placing of a modifier indicator of “0” [no modifier allowed to be used to bypass edit] for the reporting of 77295, 3-dimensional radiotherapy plans, including dose-volume histograms, in conjunction with 77300 Basic radiation dosimetry calculation. The specialty societies argued that the work of CPT 77300 was bundled into Isodose planning codes 77305, 77315, 77326, 77327 and 77328, but 77295 was specifically excluded from the April 2014 bundling request by the Joint CPT/RUC Workgroup and Relativity Assessment Workgroup. In addition, when CPT 77295 was revalued in February 2013, the work described by CPT code 77300 was not accounted for in its valuation.
The ACR and ASTRO will continue to strongly oppose and work to reverse the 77295/773000 edit as there is no duplication of work or practice expense.