by ZHealth Publishing
2024 CCI Narrative Language Update
Every year in December, the new National Correct Coding Initiative (NCCI) manual narrative instructions are released. While numerical edits of what CPT or HCPCS codes can or cannot legitimately be assigned (from a compliance perspective) are updated on a quarterly basis, the actual verbal instructions are only updated once per year.
In the update released this December (2023), which provides guidance on what may or may not be done in 2024, the following instruction was released pertaining to CPT code 76937. This information is verbatim from the CCI Manual. This is found in Chapter 9 and is part of the section labeled “General Policy Statements”:
12. Radiological supervision and interpretation codes include all radiological services necessary to complete the service. CPT codes for fluoroscopy/fluoroscopic guidance (e.g., 76000, 77002, 77003) or ultrasound/ultrasound guidance (e.g., 76942, 76998, 76937) shall not be reported separately.
Of note is the information found in the “red” colored font. This denotes a change from the previous year’s manual which stated the following:
12. Radiological supervision and interpretation codes include all radiological services necessary to complete the service. CPT codes for fluoroscopy/fluoroscopic guidance (e.g., 76000, 77002, 77003) or ultrasound/ultrasound guidance (e.g., 76942, 76998) shall not be reported separately.
As evident, the code “76937” was not present in the 2023 instructions.
This 2024 instruction change is set to have a major impact for facilities and physician practices that compliantly document the use of and submit this code (76937) when following CPT documentation instructions.
At this point, ZHealth has had conversations with several national societies regarding this change and ZHealth has been told that these societies are in the process of appealing this change.
What to do?
ZHealth recommends that until the specialty societies receive a response from CMS on whether this new instruction is repealed, to remain compliant with this 2024 language, facilities/practices should not submit CPT code 76937 with any other code for services provided on the same date of service at the same patient encounter/session that contain the verbiage “radiological supervision and interpretation” in their CPT description (this includes, but is not limited to all 70,000 angiography series codes [e.g., 75710], bundled imaging codes [e.g., 36221–36228, 36901, etc.] and bundled interventional codes, [e.g., 37220–37235, 37236–37239, 37246–37249, etc.]). These may also be referred to as “S&I codes” or “RS&I codes”.
ZHealth also recommends that facilities/practices keep a record/log memorializing patients that would have had CPT code 76937 assigned prior to this (2024) instruction. This record/log will provide assistance if this instruction is repealed, and it becomes (again) allowed to assign code 76937 with other S&I codes.
ZHealth will closely monitor this scenario and pass on any updated information when we are made aware of this.
NEW! Updated for 2024!
CPT Coding Updates for Interventional Radiology, Cardiology, and Vascular and Cardiothoracic Surgery
This ZHealth Publishing webinar includes a high level overview of the extensive 2024 coding changes to interventional radiology, cardiology, cardiothoracic surgery, and vascular surgery.
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