This page addresses follow-up questions and additional information pertinent to our webinar
Ensure Your Coding is Correct with Medicare National Coding Initiative Edits (NCCI)
** The coding information and guidance are valid at the time of publishing. Learners are encouraged to research
subsequent official guidance in the areas associated with the topic as they can change rapidly.

Q: Do Medicare NCCI edits apply to Medicaid claims?
A: Medicare NCCI edits do not apply to Medicaid; there are separate NCCI edits for the Medicaid program. The Medicaid NCCI program has significant differences from the Medicare NCCI program. Differences include Medicaid MUE edits apply to each line of a claim, whereas most Medicare MUE edits apply to the date of service. Additionally, the Medicaid NCCI program has unique edits; for example, edits for codes not covered or not separately payable by the Medicare Program. Please see MLN9018659-How-to-Use-the-Medicaid-National-Correct -Coding-Initiative-(NCCI)-Tools (cms.gov) for additional information.

Q: Is it appropriate to use modifier 59 with all NCCI PTP edits?
A: CMS notes that modifier 59 is associated with considerable abuse and high levels of manual audit activity; additionally, modifier 59 is more commonly (and frequently incorrectly) used to define a distinct service. CPT instructions state that the modifier -59 should not be used when a more descriptive modifier is available. CMS established four –X modifiers to define specific subsets of modifier -59:
XE- Separate Encounter, A Service That Is Distinct Because It Occurred During A Separate Encounter
XS- Separate Structure, A Service That Is Distinct Because It Was Performed On A Separate Organ/Structure
XP- Separate Practitioner, A Service That Is Distinct Because It Was Performed By A Different Practitioner
XU-Unusual Non-Overlapping Service, The Use Of A Service That Is Distinct Because It Does Not Overlap Usual Components Of The Main Service
Additionally, anatomical modifiers and global surgery modifiers should be utilized when appropriate and with supporting documentation.
Please see mm8863 (hhs.gov) for additional information.

Q: May an add-on code be billed and paid without a primary code?
A: No; an add-on code is only eligible for payment when the code is reported with the appropriate primary procedure performed by the same practitioner. Add-on codes billed without their primary codes are considered an overpayment. Please see SE1320.pdf (hhs.gov) for additional information.

Tamara Jones, RHIT, CPC, CPMA, CRC

Tamara Jones, RHIT, CPC, CPMA, CRC

Senior Coding Quality Auditor

Tamara brings over 15 years to Haugen’s team of Coding Quality Auditors & educators. She began her career as a denials specialist, instilling the importance of accuracy from the start! Tamara has a very investigative, analytical mindset which guided her through the roles as claims and coding managers, finding her fit as an auditor. Tamara enjoys reviewing coding assignments, digging into the clinical documentation, and working with clients to share opportunities for improvement. She has identified opportunities for clients to improve clinical documentation, identify deficiencies in processes or guidelines, and provide education to help their staff excel!

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