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CMS Announces Proposed RAC Audit Topics Including Manual Wheelchairs and Imaging Services

Jan 30, 2020

The Centers for Medicare & Medicaid Services (CMS) has announced several proposed new topics for audits which may impact a significant number of Academy members across practice settings.  Proposed topics include:

  • Manual Wheelchairs: Medical Necessity and Documentation Requirements (affected codes: K0001 and K0003)
  • Procedures that Include Imaging: Unbundling (affected codes: 70010-79999)
  • Procedures that Include Ultrasound: Incorrect Coding (affected codes: 10021, 20605, 20610, 32554, 32556, 49082 , 76492 and 76998)

In anticipation that these topics may be approved, and audits may occur, we recommend reviewing your records to confirm correct coding and documentation.

For education regarding medical necessity and documentation requirements for manual wheelchairs, please review Medicare’s provider compliance tips.  Members billing for imaging performed with procedures should pay close attention to the procedure’s CPT code descriptor.  If imaging is included in the code descriptor for the procedure, billing separately for the imaging is considered unbundling, which is incorrect coding.  If this type of incorrect coding were to be identified in an audit, the provider might be required to pay back funds for the unbundled imaging. 

Your Academy will notify members if the above described audit topics are approved by CMS.