CCI Errors: Some Moderate Sedation Pay May Be Delayed Until April

CCI Edit Alert


Seeing the new 2017 moderate sedation codes appear among the 99,490 new National Correct Coding Initiative (NCCI or CCI) edits wasn’t really a surprise, but a handful of those edits just might cause you some headaches all the same. The culprit? Modifier indicators. The good news? There should be a correction in the next version.

Here’s the Problem for Moderate Sedation

According to an announcement sent out by Medicare contractor National Government Services (NGS), the NCCI contractor has reported an error in the Jan. 1, 2017, version of the edits.

New moderate sedation codes 99151-99153, which apply when a provider performs both the moderate sedation and the procedure, were bundled incorrectly into more than 30 procedure codes. The problem edits have a modifier indicator of 0, which means you can’t override the edits.

Here Are the Codes Involved

NGS lists the following codes as the ones impacted by the issue:

  • 0424T-0436T for services related to neurostimulator systems for treatment of central sleep apnea
  • 0459T-0461T for implanted aortic counterpulsation ventricular assist device services
  • 36901-36909 for dialysis circuit services
  • 37246-37249 for transluminal balloon angioplasty
  • 43210 for esophagogastroduodenoscopy with fundoplasty
  • 45399 for an unlisted colon procedure
  • 45990 for an anorectal exam.

The announcement also lists intracranial balloon dilatation code 61640, but the January 2017 CCI edits do not include edits for 61640 with 99151-99153. There are edits bundling moderate sedation codes 99155-99157 into 61640 with a modifier indicator of 0. Keep in mind that 99155-99157 are reported by a provider who administers moderate sedation but does not perform the related procedure.

Total speculation: It’s possible including 61640 was a typo, and NCCI meant to identify another code, such as 61645 for intracranial thrombectomy and thrombolysis. Code 61645 is currently bundled with 99151-99153 with a modifier indicator of 0. But that’s a guess, and you shouldn’t base your coding on a guess. Watch for an update to this post when more information becomes available from Medicare.

[Update: The erroneous error involves 61645 and not 61640. You can see the complete listing of codes in a letter from the CCI contractor to the American College of Radiology (ACR).]

Here’s How You Should Handle the Issue

The plan is for the errors to be corrected in the next version of NCCI, which will be effective April 1, 2017.

The NGS announcement states that NCCI recommends delaying submission of your claims for 99151-99153 when performed with one of the problem procedure codes. Once the next version is implemented April 1, you can submit the delayed claims for payment. If you do submit these claims before the April correction, you can appeal the denial after April 1.

How About You?

Do these errors affect your claims? Will you delay submitting the codes, or will you submit them and appeal denials that come in


Deborah works on a wide range of TCI SuperCoder projects, researching and writing about coding, as well as assisting with data updates and tool development for our online coding solutions. Since joining TCI in 2004, she’s covered the ins and outs of coding for radiology, cardiology, oncology and hematology, orthopedics, audiology, and more.

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