0150-Mohs Micrographic Surgery: Incorrect Coding and Incorrect Units Billed

Dynamic List Information
Dynamic List Data
Issue Name
0150-Mohs Micrographic Surgery: Incorrect Coding and Incorrect Units Billed
Review Type
Complex
Provider Type
Professional Services
MAC Jurisdiction
All A/B MACs
Date
2019-03-05
RAC Type
Approved

Description

Mohs Micrographic Surgery is a two-step process in which: 1) The tumor is removed in stages, followed by immediate histologic evaluation of the margins of the specimen(s); and 2) Additional excision and evaluation is performed until all margins are clear.  This review will verify that the physician who performs the Mohs surgery is acting as both surgeon and pathologist.  Codes 17311 and 17313 are used for the first layer (stage) only and include the work of excision and pathology of up to five tissue blocks.  These codes are not targeted as it is assumed all patients will have first stage but these codes may be used to validate that the physician is acting as both surgeon and pathologist. Reviewers will determine if the correct number of units have been billed for additional Mohs micrographic technique staging unit(s) for HCPCS 17312 and 17314. Billing of excessive or insufficient units or a change in coding could result in an over- or underpayment and will be adjusted accordingly.

Affected Code(s)

17312,17314                                                

Applicable Policy References

1. Social Security Act (SSA), Title XVIII- Health Insurance for the Aged and Disabled, Section 1862(a)(1)(A)- Exclusions from Coverage and Medicare as a Secondary Payer
2. Social Security Act (SSA), Title XVIII- Health Insurance for the Aged and Disabled, Section 1833(e) - Payment of Benefits
3. 42 CFR §405.929- Post-Payment Review
4. 42 CFR §405.930- Failure to Respond to Additional Documentation Request
5. 42 CFR §405.980- Reopening of Initial Determinations, Redeterminations, Reconsiderations, Decisions, and Reviews, (b)- Timeframes and Requirements for Reopening Initial Determinations and Redeterminations Initiated by a Contractor; and (c)- Timeframes and Requirements for Reopening Initial Determinations and Redeterminations Requested by a Party
6. 42 CFR §405.986- Good Cause for Reopening 
7. Medicare Program Integrity Manual, Chapter 3 Verifying Potential Errors and Taking Corrective Actions; §§3.1-3.6.6 
8. AHA Coding Clinic for HCPCS, Third Quarter 2013, Volume 13, Number 3, Page 1-3 Reporting MOHS micrographic surgery (MMS)
9. CPT Assistant, October 2014, Volume 24, Issue 10, Page 14-Frequently Asked Questions, Surgery-Integumentary System, Mohs Surgery, Tissue Block 
10. CPT Assistant, November 2006, Volume 16, Issue 11, Pages 1-7 Mohs Micrographic Surgery
11. CPT Assistant, February 2014, Volume 24, Issue 2, Page 10-Coding Clarification: Mohs Surgery (17311-17315)
12.  AMA CPT Codebook