CMS releases updated CAR-T billing instructions

On May 28, CMS released new instructions for reporting HCPCS codes and revenue codes for chimeric antigen receptor (CAR) T-cell therapy. The revised instructions, issued through Special Edition MLN Matters 19009, replace those issued on March 15 via the April update to the Outpatient Prospective Payment System (OPPS).

SE19009 notes that the 2019 OPPS continued pass-through payment status for CAR-T HCPCS codes Q2041 and Q2042. Hospitals may report revenue codes 087X and 089X on claims submitted on or after April 1, 2019.

The article also discusses reporting codes used to report the various steps required to collect, prepare, transport, receive, and administer genetically modified T cells. Although hospital outpatient departments may report CPT® codes 0537T, 0538T, and 0539T (which report the steps to collect, prepare, transport, and receive the cells) to track CAR-T provided in the outpatient setting, Medicare will reject those lines as it does not separately pay for those services under the OPPS. Medicare currently only pays for the administration of CAR-T in a hospital outpatient setting under CPT code 0540T with revenue code 0874. If hospitals are billing charges separately to track the non-administration steps involved in CAR-T in the outpatient setting, they must report:

• HCPCS 0537T with revenue code 0871
• HCPCS 0538T with revenue code 0872
• HCPCS 0539T with revenue code 0873

SE19009 also includes several example scenarios to illustrate how to report items and services related to CAR-T in clinical scenarios. Hospitals should ensure their billing staff are aware of the new instructions.