CMS issued a new transmittal updating previous guidance on the CPT codes that can be reported with 77301 for developing an IMRT treatment plan. Currently, the following guidance applies to CPT code 77301 in both the hospital and the freestanding setting:

“Payment for the services identified by CPT codes 77014, 77280, 77285, 77290, 77295, 77305 through 77321, 77331, and 77370 are included in the APC payment for CPT code 77301 (IMRT planning). These codes should not be reported in addition to CPT code 77301 when provided prior to or as part of the development of the IMRT plan.”

Note: Please see CMS Change Request 9658 for additional information.

CMS and the NCCI removed the current edit prohibiting the reporting of CPT codes 77295 and 77300 together in the July version of the NCCI Manual. ASTRO strongly opposed the implementation of this edit, and worked with CMS to successfully appeal the edit. The change is currently in effect. See ASTRO's coding guidance on how to report claims for 77295 and 77300 to Medicare and private payers.

CMS has updated previously issued guidance on several radiation oncology CPT codes in a Change Request. The transmittal revises the language that was issued in the 2016 OPPS final rule regarding the CPT codes that can be reported with 77301 for developing an IMRT treatment plan. Currently, the following guidance applies to CPT code 77301:

“Payment for the services identified by CPT codes 77014, 77280, 77285, 77290, 77295, 77305 through 77321, 77331, and 77370 are included in the APC payment for CPT code 77301 (IMRT planning). These codes should not be reported in addition to CPT code 77301 when provided prior to or as part of the development of the IMRT plan.”

The transmittal also provides updated information on the "CP" modifier affecting CPT codes 77372 and 77373 for SRS delivery. The guidance in the Change Request is in effect. Please see CMS Change Request 9549 for additional information.

ASTRO submitted comments on the Work Plan released by the Department of Health and Human Services, Office of the Inspector General (HHS-OIG). The Work Plan lists IMRT as one of the target areas for potential improper billing practices in the hospital outpatient setting. ASTRO submitted a letter asking that the HHS-OIG take into consideration the conflicting available guidance regarding IMRT planning, and to limit its review of Medicare outpatient payments for IMRT services to those claims submitted after CMS issued clarifying guidance in the final rule. 

Previously, CPT code 77014 was incorrectly assigned a status indicator of 2 by some Medicare Administrative Contractors (MACs), which allowed only the professional component of the code to be recognized. ASTRO reached out to CMS to rectify the issue, and the status indicator has been corrected. The current status indicator for CPT code 77014 is 1, meaning that both the professional and technical component will be appropriately recognized. Please see CMS Change Request 9531 for additional information.