CMS clarification leads to more confusion over bilateral indicator for new HCPCS code

July 2nd, 2018

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains a CMS clarification in an OPPS update that affects hospital outpatient reporting for a new HCPCS code. It is aimed at coding, billing, reimbursement, and compliance professionals who work with hospital outpatient payment rules, critical access hospital billing, and modifier usage. The discussion focuses on the broader policy context, the bilateral reporting framework, discontinued-procedure modifiers, and the payment impact of the guidance.

Why This Topic Matters

Hospitals and coding professionals need to understand how CMS outpatient guidance affects claim reporting and payment under OPPS and cost-based methodologies. The article highlights a policy interpretation issue that can change reimbursement and influence how claims are reviewed and corrected.

Article Sections

  1. Key definitions

    Defines broad concepts used in the article, including bilateral reporting concepts and the general framework for discontinued procedures under hospital outpatient rules.

  2. Three billing scenarios

    Reviews general hospital outpatient and critical access hospital payment scenarios involving terminated procedures and the reporting of discontinued services.

  3. Limitations on the use of modifiers -73 and -74

    Summarizes CMS limitations and discusses the broader implications of applying discontinued-procedure modifiers in the context of the new HCPCS guidance.

  4. Next steps

    Describes the retroactive timing of the update and notes that hospitals and CAHs may need to review affected claims and monitor CMS follow-up.

What You Will Learn

  • How CMS outpatient guidance is affecting reporting for a newly added HCPCS code
  • How the article frames bilateral concepts in hospital outpatient coding
  • What general payment settings and claim review issues are involved
  • Why discontinued-procedure modifier guidance is central to the discussion
  • What types of providers and facilities are affected by the update

Who Should Read This

  • Hospital outpatient coders
  • Medical billing professionals
  • Revenue cycle staff
  • Compliance officers
  • Health information management professionals
  • Critical access hospital staff

Codes Discussed

  • HCPCS Level II: C9749
  • HCPCS Level II: -73
  • HCPCS Level II: -74
  • HCPCS Level II: -76
  • HCPCS Level II: -77
  • HCPCS Level II: -50
  • HCPCS Level II: -52
  • HCPCS Level II: J1

Modifiers Discussed

  • HCPCS Level II: -73
  • HCPCS Level II: -74
  • HCPCS Level II: -76
  • HCPCS Level II: -77
  • HCPCS Level II: -50
  • HCPCS Level II: -52

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