Q&A: Deciphering 2020 radiation therapy guideline updates

October 4, 2019
Medicare Web

Q: Our coding team saw that there is a new section for radiation therapy in the fiscal year (FY) 2020 ICD-10-PCS Official Guidelines for Coding and Reporting. Can you explain the recent changes made to this section?

A: Yes, you’re right. The section you are referring to, Section D, is no longer titled New Technology, but has been updated to Radiation Therapy. CMS moved the new technology guidelines to Section E.

The new set of guidelines for reporting radiation therapy were developed in response to public comment. Previously, ICD-10-PCS codes for low-dose-rate brachytherapy didn’t specify the application used to administer unidirectional radiation.

Under many new therapy regimens, seed devices deliver a full dose of radiation to surgical margins, while radiosensitive and healthy tissues are shielded by the device from unnecessary and potentially harmful radiation. Treatments like this allow for clinically effective doses of radiation to be delivered without spreading toxicity to adjacent tissues.

The FY 2019 ICD-10-PCS code set also didn’t include codes to specify all the treatment sites for which brachytherapy may be used. For example, leading treatment regimens like CivaSheet®, an implantable unidirectional low-dose brachytherapy device applied intraoperatively, may be used in treatment sites beyond those described by 2019 ICD-10-PCS codes.

The FY 2020 ICD-10-PCS radiation therapy guidelines provide two specific clarifying instructions: coding brachytherapy at the end of a procedure and as a separate procedure.

For guidance on brachytherapy at the end of a procedure new subsection, D1.a, states:

Brachytherapy is coded to the modality Brachytherapy in the Radiation Therapy section. When a radioactive brachytherapy source is left in the body at the end of the procedure, it is coded separately to the root operation Insertion with the device value Radioactive Element.

The 2020 guidelines include two specific examples illustrating correct application of this guideline.

For reporting brachytherapy as a separate procedure, new subsection, D1.b, states:

A separate procedure to place temporary applicator for delivery of the brachytherapy is coded to the root operation Insertion and the device value Other Device.

CMS reported that the new guidelines for the Radiation Therapy section include subsections D1.a, D1.b, and D1.c; however, it did not print a subsection titled D1.c. CMS may have made an error in the summary report—either there truly is no section D1.c, or CMS forgot to publish this section. If it was an omission, be on the lookout for an erratum to the coding guidelines.

Editor’s Note: Joe Rivet, JD, CCS-P, CPC, CEMC, CHC, CCEP, CHRC, CHPC, CICA, CPMA, CAC, CACO, partner with the American Regulatory Compliance Society in Grand Haven, Michigan, answered this question.

This answer was provided based on limited information. Be sure to review all documentation specific to your own individual scenario before determining appropriate code assignment.

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