Q: What CY 2016 CPT codes are affected by the NEMA standard and what is the penalty?
A: The CY 2016 Final Rule implements a provision that penalizes the Technical Component (TC) providers of Computed Tomography (CT) procedures when the CT system does not meet the National Electrical Manufacturers Association (NEMA) Standard XR-29-2013¹. CT systems failing the standard will face a penalty of 5% beginning January 1, 2016. This penalty increases to 15% January 1, 2017. CY 2016 CPT codes subject to the NEMA standards are:
70450 - 70498; 71250 - 71275; 72125 - 72133; 72191 - 72194; 73200 - 73206;
73700 - 73706; 74150 - 74178; 74261 - 74263 and 75571 – 75574².

Q: How do I indicate a CPT code failed to meet the NEMA standard?
A: This is applicable only in a non-facility Place of Service (POS) and is applicable to the TC and the TC portion of global billing. CMS has created a new modifier, "CT," that is to be applied to the appropriate CPT code when the NEMA standard has not been met. For those procedures coded with one of the above CPT codes and a TC modifier is used, a CT modifier should also be added to indicate the NEMA standard was not met. A global service where neither the TC or 26 (Professional Service) modifiers are used would also be billed with the “CT” and the reduction will be applied to the technical component only³.

Q: Does this apply to PET with CT?
A: The rule does not apply to other CT procedures such as CT simulation for radiation therapy or PET/CT. However, if the same PET/CT scanner is also used for a diagnostic CT study that uses a CPT code from the CMS list above, it is covered by the rule and subject to the “CT” modifier if the system is non-compliant.

¹Revisions to Payment Policies under the Physician Fees Schedule and other Revisions to Part B Final Rule for CY Fed. Reg. 220, (Nov. 16, 2015) (to be codified at 42 CFR Parts 405, 410, 411, 414, 425, 495 et al.). 2016, 80. Page 70931.
²Ibid at page 70930.
³MLM Matters Number 9250 Nov. 6, 2015 Pages 3 and 4.

Author - Male

About the author

Nicholas Parish of Compliance – Radiology, McKesson Business Performance Services.