On April 2, CMS released Program Memorandum (PM) A-03-020, which states, "Codes 77401 through 77416 may be reported more than once per date of service only when radiation treatment is provided during completely different sessions. Only one of these codes may be reported for each treatment session no matter how many areas are treated or no matter how much radiation is delivered."
This PM corrected CMS'Jan. 3 transmittal (A-02-129), which incorrectly advised radiation oncologists to report these codes only once per date of service. Look at the 'Nature of the Services' Although CMS does not define "completely different sessions," most Medicare carriers agree that you must maintain a six-hour break between the radiation treatments. In addition, the patient's medical record must clearly document the medical necessity of separate session scheduling (also referred to as "BID" or "hyperfrac-tioning"). Empire Medicare's (the Part Acarrier for New York, Massachusetts, Delaware and Connecticut) policy echoes most others'when it states that the individual sessions must be "of the character usually furnished on different days."
"You have to look at the nature of the radiation services," says Deborah I. Churchill, RTT, president of Churchill Consulting Inc., a Killingworth, Conn., consulting firm that offers audits, seminars and electronic coding applications. "To bill two radiation treatment codes, the separate sessions have to be of the type of services that you would normally perform on different days."
"Suppose you treat a patient in the morning with two separate areas," Churchill says. "This constitutes only one treatment delivery code because you would normally address both of these areas during one session."
If you administer two completely unique treatments to the patient on the same day, however, you should report two separate treatment encounters using the appropriate code(s). For example, "If a patient had a head or neck cancer, such as T1 cancer of the larynx (161.0-161.9), we might administer a lower-than-normal dosage of radiation to the patient, but we do that twice a day," says Diane Corder, RTT, facility administrator at Gwinnett County Radiation Therapy Center in Lawrenceville, Ga. "The per-treatment dosage is lower, but the overall dosage is higher than normal. The one caveat that the insurer requires is that we allow a minimum of six hours between therapies so the normal cells can recuperate." If you meet those requirements, you can report both codes on the same date. Churchill agrees. "The standard 'BID'break, based on utilization guidelines, is approximately six hours. This technique is generally [...]