UPDATED: CMS spoke softly and made big changes to NCCI edits

by Julia Kyles, CPC on Apr 16, 2020

Update: CMS has updated the NCCI section of the CMS website to state that the changes announced in its April 7 NCCI updates reported below are retroactive to Jan. 1 -- so code accordingly.

Replacement Files (2nd quarter of 2020) – related to the COVID-19 Public Health Emergency: In accordance with Centers for Medicare & Medicaid Services’ (CMS) expansion of telehealth services, CMS updated procedure-to-procedure (PTP) edits and Medically Unlikely Edits (MUEs) for Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes, retroactive to January 1, 2020.

(Original post:)

There was no fanfare when CMS released replacement files for the April update to the national correct coding initiative edits (NCCI) updates, April 7. But the changes deleted 29,1902 procedure-to-procedure (PTP) edits and 197 medically unlikely edits (MUE).

Subscriber content: Download a spreadsheet of the PTP and MUE deletions for practitioners and share it with your staff.

The interim final rule published March 31 hinted at the MUE changes. One provision of the rule announced frequency limits for some services would be eliminated in order to facilitate the use of telehealth and other communications-based services.

Telehealth services, including those that CMS added on a temporary basis during the COVID-19 crisis, dominate the list of deleted or “temporarily suspended” MUEs. However, the list includes E/M services conducted by telephone (99441-99443) online (99421-99423), as well as Medicare’s virtual visits (G2010 and G2012).

Deleted PTP pairs include E/M visits, anesthesia services and procedures. Again, check out our spreadsheet and use the filter and sort functions to determine whether your services are impacted.

The updated files will make it easier for practices to treat patients during the COVID-19 emergency, but there’s a one-month disparity between the March 1 effective date for COVID-19 changes and the effective date for the April PTP and MUE updates. Does this mean, for example, that if a practice performed telephone E/M services — which normally have an MUE of 0 — before April 1, it will receive a denial that it must appeal?

We’ll ask CMS for a resolution and update this post when we have an answer. Stay tuned.

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