Proposed Rule Comment Period Opportunity for 27279, Minimally Invasive SI Joint Fusion
August 29, 2019
ISASS Comments on Medicare Physician Fee Schedule CY 2020 Proposed Rule, Address Misvaluation of 27279
September 30, 2019
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In a letter dated Aug. 16, ISASS responded to a decision by CMS and CMS’ NCCI Edit Contractor, Capital Bridge LLC, to not revise a set of  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.

In early 2019, 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 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), ISASS 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.

Subsequent to the April 19, 2019 letter, 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.

In a June 11, 2019 letter from ISASS provided additional information to CMS and NCCI.  NCCI indicated they would provide a formal response within 6-8 weeks. NCCI provided their response via email July 25, 2019 and ISASS responded with a formal letter on Aug. 16, 2019.

ISASS will continue to push for changes in these edits moving forward and will provide members updates on any responses in the coming weeks and months.

ISASS CCI 22842-22845 Letter

ISASS CCI 22842-22845 follow up letter

ISASS CCI 22842-22845 Response