ISASS Asks For Changes to National Correct Coding Initiative (NCCI) edits for Spinal Instrumentation Codes

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In a letter dated April 16, 2019, ISASS asked for CMS to consider changes to a set of National Correct Coding Initiative (NCCI) edits for CPT codes 22842, Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and sublaminar wires); 3 to 6 vertebral segments (List separately in addition to code for primary procedure), 22843, Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and sublaminar wires); 7 to 12 vertebral segments (List separately in addition to code for primary procedure), 22844, Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and sublaminar wires); 13 or more vertebral segments (List separately in addition to code for primary procedure) 22845, Anterior instrumentation; 2 to 3 vertebral segments (List separately in addition to code for primary procedure).  The edits in question were implemented by CMS through the NCCI edit process in 2017 and were intended to allow for use of the codes with appropriate other procedure codes with use of CMS/CPT modifiers.

It was reported to ISASS that some CMS carriers were not implementing the NCCI edits appropriately, even when modifiers were being used, and spine surgeons have been receiving denials from Medicare when using CPT codes 22842-22845. ISASS wrote the letter to inform NCCI and CMS of the problem with inappropriate denials and stated that in previous communications to NCCI—at the time the edits were proposed—that ISASS, along with the American Association of Neurological Surgeons (AANS), the Congress of Neurosurgeons (CNS), the North American Spine Society (NASS), and the American Academy of Orthopaedic Surgeons (AAOS), stated the edits were unnecessary and could lead to inappropriate denials.  Given the reporting of denials by practitioners, ISASS stated the most appropriate action would be to delete the edits all together.

In response, NCCI wrote back via email to ISASS on April 29, 2019 stating they would review the request with CMS and seek additional feedback from ISASS and others on future actions.  NCCI thanked ISASS for raising the issue.

Read the ISASS letter: ISASS CCI 22842-22845 Letter: