Thursday, January 02, 2020 Time to Act: Surprise Coding Complication Ignores Realities of PT Practice and Must be Changed NOTE: While comments to this story are welcome, if you want to add your voice to the advocacy effort, please follow the "what you can do" instructions in the last paragraph to contact the NCCI contractor directly. Thanks! The US Centers for Medicare and Medicaid Services (CMS) unveiled an unwelcome New Year's Day surprise for outpatient therapy providers, including private practitioners and facility-based settings, when it announced it will no longer allow two frequently used therapy billing codes to be used in combination with evaluation codes. It's a decision that flies in the face of standard PT practice and effective patient care—and CMS and the National Correct Coding Initiative (NCCI) contractor need to hear that perspective loud and clear, from as many stakeholders as possible as soon as possible. At issue are current procedural terminology (CPT) codes 97530 (therapeutic activities) and 97150 (therapeutic procedures, group, 2 or more individuals) which, until January 1, were allowed to be billed on the same day as physical therapy or occupational therapy evaluation. Under new CMS NCCI edits, however, that's no longer allowed. And in a further complication, the latest NCCI edits also require use of the 59 modifier—the modifier that's used to indicate that a code represents a service that is separate and distinct from another service to which it is paired—whenever code 97140 (manual therapy) is billed with an evaluation. [Editors' note: to view the full list of edits that went into effect January 1, visit the CMS PTP coding edits webpage, and scroll down to the "related links" area, where you can select your setting to find out what's changed.] The problem, according to APTA Director of Regulatory Affairs Kara Gainer, is that the changes ignore accepted PT practice, which often includes the startup of care on the same day as evaluation, as well as continuation of care on the same day as revaluation. "The whole NCCI process is supposed to put a check on payment for codes that represent overlapping services," Gainer said. "These edits not only miss that mark, they actually have the effect of restricting patient access to the most effective, efficient care, and risking a patient's ability to achieve the best possible outcomes." APTA usually receives notice of intended NCCI edits well in advance. That didn't happen in this case, making it imperative that the association, its members, and other stakeholders take action quickly to convince NCCI to reverse its decision. APTA is in communication with Capitol Bridge, LLC, CMS' NCCI contractor, as well as with the American Medical Association, to press for a resolution to the problem. What you can do: APTA has developed a comment letter template that you can fill in with your personal information and email to Capitol Bridge, LLC, at NCCIPTPMUE@cms.hhs.gov. Make your voice heard.