Comment Letter

Neurosurgery Leads Effort to Rescind Edit for Spinal Decompression Codes

  • Reimbursement and Practice Management

Pamela Villanyi, MD, Medical Officer
Centers for Medicare & Medicaid Services
CMS NCCI Program Team
Audits and Vulnerabilities Group
Center for Program Integrity
7500 Security Boulevard
Baltimore, MD 21244-1850
Pamela.villanyi@cms.hhs.gov

Submitted electronically via NCCIPTPMUE@cms.hhs.gov

SUBJECT: NCCI PTP Edits for Column 1 CPT codes 22630, 22632, 22633 and 22634 with Column 2 CPT codes 63052 and 63053

Dear Dr. Villanyi:

On behalf of the American Association of Neurological Surgeons (AANS), the Congress of Neurological Surgeons (CNS), the American Academy of Orthopaedic Surgeons, the International Society for the Advancement of Spine Surgery and the North American Spine Society, we are writing regarding the recent notification by the CMS National Correct Coding Initiative (NCCI) staff informing us that as of July 1, 2023, NCCI edits will be implemented that restrict the reporting of spinal fusion codes 22630, 22632, 22633 and 22634 with add-on decompression CPT codes 63052 and 63053. In the same notice to our societies, CMS also acknowledged this was an error, and they will delete this edit as soon as technically possible, with the deletion being retroactive to the implementation date of July 1, 2023. We have notified our members of this communication. However, we need further clarification and guidance regarding the appropriate use of a modifier to permit the reporting of CPT codes 63052 and 63053 with CPT Codes 22630, 22632, 22633, and 22634 until the edit is removed.

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