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CMS has Revised NCD 20.4 – Guidance for Implementation Period

Libman Education is proud to offer ZHealth Publishing’s broad range of coding products to assist both the novice and the seasoned coder to become experts at coding and charging for complex procedures in Interventional Radiology, Interventional Cardiology, Vascular/Endovascular Surgery, and Diagnostic Radiology. Periodically, ZHealth Publishing experts offer general recommendations in response to specific customer inquiries.

by David Zielske, MD, CIRCC, COC, CCVTC, CCC, CCS, RCC

“The revised NCD is retroactive to 02/15/18; however, the implementation date is not until 02/26/19, so the -Q0 modifier will be required until February 26, 2019.”

Could you please clarify what retroactive means? What is required during the period between the retroactive date and the implementation date? Does it mean that we do not have to submit patients to the NCDR – ICD registry after 2/15/18? Or, do we have to submit these patients to the registry until 2/26/19? Thank you.

It means that the MAC’s software won’t be updated to remove the requirement of the -Q0 modifier until 02/26/19. On 02/26/19 the -Q0 requirement will be removed from the MAC’s edits going back to 02/15/18. Until 02/26/19, you can choose to submit the data to the registry and bill with the -Q0 modifier until the implementation date, or choose not to submit the data to the registry, which requires you to hold the claim and bill it no earlier than 02/26/19.

Note:  Dr. Zielski’s description of the revision to NCD 20.4 can be viewed here.


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About the Author

David Zielske is founder and President of ZHealth Publishing and primary author and editor of ZHealth publications. Dr. Z practiced as an interventional radiologist and has over twenty years experience as a coding reviewer and coding expert. He is Board Certified in Radiology and has functioned as an independent interventional radiology, vascular surgery, and cardiovascular coding consultant to a variety of physician groups and hospital providers across the country. He also served as an instructor for over 200 coding seminars.

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