February 15, 2011

New Untimed Code: Canalith, Outpatient Providers Beware!

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nbeckleyOutpatient physical therapists who have been providing canalith repositioning for their patients have been instructed by CMS to bill this procedure with CPT code 95992 effective immediately.

Canalith repositioning is a treatment for benign paroxysmal position vertigo (BPPV), which is caused by crystals floating in the fluid of the inner ear. Prior to now the canalith repositioning code was considered bundled with codes utilized by other providers, most notably evaluation & management (E&M) codes. As a result, CMS in 2009 instructed the therapy community (MM6397) to utilize CPT code 97112, for neuromuscular reeducation, to report use of the canalith repositioning procedure, the Epley Maneuver or the Semont Maneuver.

The neuromuscular reeducation code is a timed code requiring one-on-one direct contract with the physical therapist, and it is billed in increments of 15 minutes. CMS documentation requirements call for a daily therapy note to include the recording of minutes in timed codes as well as total minutes of therapy (i.e. totals in timed and untimed codes).

Timed codes are subject to the Medicare "eight-minute rule," and the total number of billed units is constrained by the total minutes in timed codes, potentially resulting in confusing documentation and billing. For example, an ultrasound procedure may take only seven minutes, but often it is not billed directly because those minutes are rolled into the total minutes in timed codes, often resulting in an additional unit of another code being billed. CMS provides guidance on the "eight-minute rule" in Chapter 5 of the Medicare Claims Processing Manual.

Now that CMS has instructed physical therapists to utilize CPT® code 95992, caution must be exercised to bill this code only once per day, a reversal from the past practice of utilizing a timed code that could be billed in units greater than one. The topic of untimed therapy codes has been on the Recovery Audit Contractors' radar in all four regions as a CMS-approved issue for automated reviews. Many providers have been caught on this issue when billing for multiple units of the same untimed procedure, such as a physical therapy evaluation or mechanical traction. Early on, it was reported by providers in Region C that demand letters related to untimed codes were issued for instances in which the provider utilized two untimed codes rather than two units of one untimed code. More recently, providers in Region A reported the same situation, with more demand letters issued for appropriate use of untimed codes.

Some key steps that can be taken to ensure compliance with CMS guidelines include the following:

  • Add CPT code 95992 to your billing system and suppress the value to a unit of 1.
  • Instruct therapists in proper billing for the canalith repositioning maneuver.
  • Reeducate all billing and therapy staff on the CMS "eight-minute rule" and how to account for all therapy services provided in the daily note.

CPT code 95992 is not subject to edits in the Correct Coding Initiative (CCI). Some good news is that this code also is not subject to the Multiple Procedure Payment (MPPR) reduction policy that is in effect for "always" therapy codes.

MPPR provides for a practice expense reduction of 20 percent on second and subsequent billed codes per day in an office setting (private practice), and a 25 percent practice expense reduction in facility settings, including hospital OP departments, rehab agencies, CORFs and SNF Part B therapy services.

About the Author

Nancy Beckley is a founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, CORFs, SNFs and private practice. Nancy is certified in healthcare compliance by the Healthcare Compliance Board.  She is on the Board of the National Association of Rehab Providers & Agencies.  She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities.

Contact the Author

nancy@nancybeckley.com

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Nancy J. Beckley, MB, MBA, CHC

Nancy Beckley is founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, and private practices. Nancy is certified in healthcare compliance by the Healthcare Compliance Certification Board. She is on the board of the National Association of Rehabilitation Providers and Agencies. She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities. Nancy is a familiar voice on Monitor Mondays, where she serves as a senior national correspondent.

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