Christine Posted Tue 16th of January, 2018 14:38:12 PM
Can you tell me if POS 11 can bill for this it is not stating POS thanks
Final Update to the December 2017 Q & A
In the seemingly never-ending saga regarding drug eluting/covered angioplasty balloon billing, the rules changed since we first published the newsletter and during our update to it. There will still be no pass-through code payment in 2018, but CMS is allowing retroactive billing for angioplasty in a dialysis fistula/graft performed with this device for a limited period in 2017. Here is the most recent information:
Drug Eluting Balloon Pass Through Payment for Use in AV Dialysis Grafts
On August 25, 2017, the FDA approved the use of a drug eluting balloon catheter for angioplasty in an AV dialysis graft. Previously HCPCS code C2623 (Catheter, transluminal angioplasty, drug-coated, non-laser) was only covered when used in the femoral/popliteal arteries. When billed with an angioplasty in the femoral/popliteal arteries, pass-through payment was made.
To address the change in FDA approval for use of a drug eluting balloon catheter last August, on January 1, 2018 CMS has added retroactive pass-through payment for a drug eluting balloon when the device is billed with either of the following two CPT codes:
36902 - Introduction of needle(s) and/or catheter(s), dialysis circuit, with diagnostic angiography of the dialysis circuit, including all direct puncture(s) and catheter placement(s), injection(s) of contrast, all necessary imaging from the arterial anastomosis and adjacent artery through entire venous outflow including the inferior or superior vena cava, fluoroscopic guidance, radiological supervision and interpretation and image documentation and report; with transluminal balloon angioplasty, peripheral dialysis segment, including all imaging and radiological supervision and interpretation necessary to perform the angioplasty.
36903 - Introduction of needle(s) and/or catheter(s), dialysis circuit, with diagnostic angiography of the dialysis circuit, including all direct puncture(s) and catheter placement(s), injection(s) of contrast, all necessary imaging from the arterial anastomosis and adjacent artery through entire venous outflow including the inferior or superior vena cava, fluoroscopic guidance, radiological supervision and interpretation and image documentation and report; with transcatheter placement of intravascular stent(s), peripheral dialysis segment, including all imaging and radiological supervision and interpretation necessary to perform the stenting, and all angioplasty within the peripheral dialysis segment.
There is no pass-through payment in 2018, so the pass-through payment will only be for claims filed retroactively for dates of service from August 25, 2017, through December 31, 2017.
Original Q&A and Update from December 2017:
Question: Drug Eluting Balloon C2623 with CPT 36902
DEB’s did receive FDA approval (PMA) for treatment of stenotic lesions in dysfunctional native arteriovenous dialysis fistulae up to 8cm in length. This occurred August 25, 2017. HOWEVER, this will not change issues with CMS pass-through payment for HCPCS code C2623. Use of a DEB in the AV fistula is now FDA approved, just not the payment. Restoration of payment for use of a DEB (C2623) in AV fistulae and femoral/popliteal arteries is to be evaluated by CMS in 2018. Societies continue to work closely with CMS to obtain payment for this product.
See comments from the FDA approval letter below. Here is the full FDA approval letter.
The Center for Devices and Radiological Health (CDRH) of the Food and Drug Administration (FDA) has completed its review of your premarket approval application (PMA) for the Lutonix® 035 Drug Coated Balloon PTA Catheter, Model 9010. The LUTONIX® 035 Drug Coated Balloon PTA Catheter is indicated for percutaneous transluminal angioplasty (PTA), after predilatation, for the treatment of stenotic lesions in dysfunctional native arteriovenous dialysis fistulae that are 4 mm to 12 mm in diameter and up to 80 mm in length. We are pleased to inform you that the PMA is approved. You may begin commercial distribution of the device in accordance with the conditions of approval described below.
Our facility is performing the AV angiography of the dialysis circuit as described in CPT code 36902. The surgery department is using the device code C2623 for the drug eluting balloon that is documented as being used by the surgeon. We are receiving denials that the drug eluting balloon code does not have a matching CPT code. From what I can find, it appears that drug eluting balloon code C2623 can only be used with fem/pop procedures; is this correct?
Yes, that is the correct code for the DEB, but it is currently only approved for and being paid in femoral/popliteal lower extremity revascularization procedures. In 2018, there may not be payment from Medicare even for lower extremity revascularizations (as currently noted in the Federal Register).
The use of a DEB in the femoral/popliteal distribution has given great results in the literature. Additionally, the non-payment issue is being addressed by several physician societies, as limiting payment for these devices may result in patient care issues (not using the technology if not reimbursed even if it is better for the patient long term outcomes). We do not know of any push for payment in the AV dialysis circuit yet.
SuperCoder Answered Wed 17th of January, 2018 04:17:22 AM
POS code 11 is for POS Name "Office", according to CMS POS description for the code is "Location, other than a hospital, skilled nursing facility (SNF), military treatment facility, community health center, State or local public health clinic, or intermediate care facility (ICF), where the health professional routinely provides health examinations, diagnosis, and treatment of illness or injury on an ambulatory basis.
Whereas, Catheter, transluminal angioplasty, drug-coated, non-lase (HCPCS C2623) is a supply code for the dialysis circuit (CPT 36902 code range) which is a big procedure and cannot not be performed without proper facilities of operating room. As per description of the code, avoid using the POS 11 for mentioned procedure.
Christine Posted Wed 17th of January, 2018 10:38:07 AM
code 36902 can be done in an POS 11 that is why I was asking the question about the supply code C2623 and if we can bill for it or is it just a facility code.
SuperCoder Answered Thu 18th of January, 2018 03:17:55 AM
For the new dialysis circuit codes, there are two key facts:
- These codes help you to target a variety of services.
- You should limit yourself to only one unit for one session.
As per CMS, codes 36901, 36902, and 36903 aren’t restricted to a single service alone.
Listed below are the services that these codes cover:
- Manipulation of catheter
- Injection of contrast, if any
- Fluoroscopic image guidance
- Road mapping for the procedure
- Radiological supervision
- Interpretation of the radiological images.
Due to the criticality and required level of care these services are usually performed at operating room, but also can be performed under office settings when equipped properly for the performed procedure. There are no specific guidelines defined by the federal body for the code C2623, however, since insurance pay the procedure (CPT 36902) under POS 11, then they have to pay the supplies (HCPCS C2623) also.