Some Modifier 59 and X{EPSU} Facts to Keep Your Practice Compliant

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With the year half over and the big push on for ICD-10 implementation, it might be easy to let your attention slip from modifiers for CPT® codes. But never fear, here we are with some more modifier coding guidelines to keep your billing practices current and your reimbursement on target through the rest of the year.

CMS Says Don’t Worry About X{EPSU} — For Now

One change you can mark off your billing compliance list, at least for now, is using the new X modifiers. CMS says it will continue to recognize modifier 59 (Distinct procedural service), even though CPT® instructions require use of a more descriptive modifier than 59 when available. The new X modifiers, also called X{EPSU}, are HCPCS modifiers in coding for subsets of modifier 59. The X modifiers help describe the circumstances that make your service “distinct,” and CMS defines them as follows:

CMS reps addressed the X{EPSU} modifier issue during a CMS Open Door Forum in April, explaining why the agency had remained silent until then. “In releasing the modifiers, we did not release instructions for the modifiers at that time the way CMS normally does, and there’s a specific reason for that,” said Dan Duvall, MD, chief medical officer with CMS’s Center for Program Integrity.

Duvall said that CMS wanted software developers to have time to make changes to incorporate these new modifier requirements into systems before requiring their use. He said that further instructions would appear at some point in the future, but for now, practices should continue to use modifier 59 for claims if they aren’t comfortable appending the X modifiers prior to release of official CMS advice on how to use them.

When a caller to the forum asked for an example of how to use modifier XU, Duvall told her, “From our standpoint there is no benefit to using it over 59.” For now, CMS says it will accept either a modifier 59 or a more selective X{EPSU} modifier as correct coding, but MACs may require the more selective modifiers sooner. The X modifiers have the same editing specifications as modifier 59.

Let Modifier Coder Alert Keep Your Coding Current

Want to be the master of modifiers? Check out Modifier Coding Alert from SuperCoder and The Coding Institute. This monthly newsletter brings you how-to articles on using different modifiers, including payer spotlights detailing a particular payer’s modifier coding guidelines. You also get answers to reader questions from readers — other coders just like you. See more here.


Susan taught health information and healthcare documentation at the community college level for more than 20 years. She has a special love for medical language and terminology. She is passionate about ensuring accurate patient healthcare documentation through education. She has a master's degree in healthcare administration, is a certified healthcare documentation specialist, and serves as immediate past president for the Association for Healthcare Documentation Integrity (AHDI).

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