RE NCCI version 9.0; CPT Codes 38720, 38724 by gox54152

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									October 2, 2002

Niles R. Rosen, M.D.
Medical Director, National Correct Coding Initiative
P.O. Box 50469
8115 Knue Road
Indianapolis, IN 46250-0469

       RE: NCCI version 9.0; CPT Codes 38720, 38724

Dear Dr. Rosen:

The edits referenced in your letter to Dr. Richard Holt of 19 August 2002 relate
to CPT 38720 [Cervical lymphadenectomy (complete)] and CPT 38724
[Cervical lymphadenectomy (modified radical neck dissection)].

       CPT 38720 [Cervical lymphadenectomy (complete)] is
       generally considered the classical radical neck dissection
       (RND). This operation includes dissection of the submandibular
       and posterior triangles as well as major neck lymphatics/nodes,
       sternocleidomastoid (SCM) muscle, spinal accessory nerve, and
       internal jugular vein. It is a unilateral procedure. Several of the
       codes in Column 1 (e.g., 31365) report a major head and neck
       resection with RND.

       CPT 38724 [Cervical lymphadenectomy (modified radical neck
       dissection)] describes a number of modifications of the classical
       RND, often leaving the internal jugular vein, SCM muscle,
       and/or spinal accessory nerve to improve patients’ quality of
       life. These are more technically challenging operations,
       justifying the physician work of 14.54 RVUs compared to the
       value for 38720 of 13.61 RVUs.

Surgeons and coders consider either type of lymphadenectomy to be unilateral
and if a RND is included in an existing CPT code, this refers to neck dissection
of one side only. For example, comparing 31360 [Total laryngectomy, 17.08
RVUs] with 31365 [Total laryngectomy with RND, 24.16 RVUs], there is a
difference of 7.08 RVUs, about half the value for stand-alone procedures. Of
the Column 1 codes, only CPT 42426 verbiage specifically states the RND to
be unilateral; for the others, it is understood.
Attached is a comment grid listing the recommendations of the American
Academy of Otolaryngology-Head & Neck Surgery for each proposed edit. It
is imperative that surgeons performing concurrent bilateral neck dissections,
radical or modified radical, be able to report and bill for the second side with
appropriate documentation and modifier(s). The additional physician work
intra- and postoperatively is not trivial; many of these patients have had prior
radiation and most go to surgery with advanced tumor staging and medical
comorbidities. Further devaluation by this proposed bundling of surgical
services for treatment of head and neck neoplasms is not in our patients’ best
interest.

Reporting of a (second-side) modified radical neck dissection (38724) in
addition to a combined resection with RND CPT code (e.g., 31365) should be
allowed. This is similar in concept to your recommendation for no change in
the existing edits for 41153.

We believe that the complexity, risk assumption, separate closure, different
instrumentation and other resources dedicated in the procedures under
discussion, warrant reimbursement at 100% of the allowable for each side and
wish to state this for the record. Our recommendations call largely for status
indicator 1 because we do not believe a 3, which we feel to be the correct
designation, would be seriously considered.

Thank you for your consideration and please contact me if I can address any
further questions or comments. I remain,

Respectfully,


David R. Nielsen, MD, FACS
Executive Vice President
(703) 519-1559

Attachment

RW:DRN:rw
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October 21, 2002

David R. Nielsen, MD, FACS
American Academy of Otolaryngology-Head and Neck Surgery
One Prince Street
Alexandria, VA 22314-3357

Lee D. Eisenberg, MD
AMA’s CPT Editorial Panel
177 N. Dean Street
Englewood, NJ 07631

Dear Dr. Nielsen:

I want to thank both of you for commenting about proposed changes to National Correct
Coding Initiative (NCCI) edits related to CPT codes 38720 (cervical lymphadenectomy
(complete)) and 38724 (cervical lymphadenectomy (modified radical neck dissection)).
We have discussed your letter and emails with CMS which owns NCCI and makes all
decisions about its contents.

CMS will implement new edits and make modifications to current edits consistent with
your suggestions recognizing that there is a reasonably high frequency of bilateral radical
neck dissections. A list of the edits and their modifier indicators is attached. Only four
edits as recommended by Dr. Nielsen have modifier indicators of “0” indicating that a
NCCI associated modifier cannot be used to bypass the edit.

These new edits and modifications of current edits will be implemented in NCCI version
9.0 scheduled for January 1, 2003.

We appreciate your assistance with the NCCI.

Sincerely,


Niles R. Rosen, M.D.
Medical Director
National Correct Coding Initiative


Cc:    Marsha Mason-Wonsley, CMS CPT Coding Specialist
       Ms. Emily Graham, AAO-HNS
                                        P.O. Box 50469
                        8115 Knue Road ● Indianapolis, IN 46250-0469
                               National Correct Coding Initiative
                         Phone: (317) 841-4400 Fax: (317) 841-4600
ATTACHMENT - Edits with 38720 and 38724
Modifier indicator of “0” means modifiers associated with NCCi are not allowed.
Modifier indicator of “1” means modifiers associated with NCCI are allowed.

Column 1 Code       Column 2 Code       Modifier indicator
31360               38720                     0      will be added
31365               38720                     1      Existing edit; no change
31367               38720                     0      will be added
31368               38720                     1      Existing edit; no change
31390               38720                     1      Existing edi; no change
31395               38720                     1      Existing edit; no change
41135               38720                     1      will be added
41140               38720                     0      will be added
41145               38720                     1      will be added
41150               38720                     0      will be added
41153               38720                     1      Existing edit; no change
41155               38720                     1      Existing edit; no change
42426               38720                     1      will be added

31360               38724                      1      Existing edit; change to
modifier
                                                      indicator 1
31365               38724                      1      Existing edit; no change
31367               38724                      1      Existing edit; no change
31368               38724                      1      Existing edit; no change
31390               38724                      1      Existing edit; no change
31395               38724                      1      Existing edit; no change
41135               38724                      1      will be added
41140               38724                      1      will be added
41145               38724                      1      Existing edit; no change
41150               38724                      1      will be added
41153               38724                      1      Existing edit; no change
41155               38724                      1      Existing edit; no change
42426               38724                      1      Existing edit ; No change

								
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