HCPCS Update Released

by Joseph McTernan, AOPA's government affairs department

Late October is an important time at AOPA because the long-anticipated annual update for the Healthcare Common Procedural Coding System (HCPCS) is released. This update is significant, of course, because prostheses and orthoses are billed using a subset of HCPCS codes.

While HIPAA regulations require all insurers to recognize HCPCS codes, the Centers for Medicare and Medicaid Services (CMS) controls the code set through its HCPCS workgroup. This workgroup is responsible for annually updating the HCPCS codes, which includes adding new codes, deleting obsolete or ineffective codes, and making changes to existing codes, when necessary. The HCPCS workgroup conducts public meetings in the spring of each year to allow the public to comment on applications for additions, deletions, or changes to the HCPCS codes. Following the public meeting, the workgroup conducts a last review and makes a final decision on each application. The updated HCPCS file is usually released in late October and implemented on January 1 of the following year.

AOPA has reviewed the recently released 2009 HCPCS file and has compiled a summary of new, deleted, and changed HCPCS codes and modifiers that are relevant to orthotics and prosthetics. (See also the table at bottom.)

Overall, the O&P HCPCS for 2009 includes relatively few changes. Two new modifiers and nine HCPCS codes have been added. One modifier and 11 codes were deleted from the HCPCS, and the descriptor for one code has been changed. As an important reminder, there is no longer a grace period for HCPCS changes: They will go into effect Jan. 1, 2009.

New Codes and Modifiers
HCPCS codes contain a letter followed by a four-digit number. L-codes are exclusive to orthotic and prosthetic devices, and certain A codes are used to describe diabetic shoes. CMS has added two new modifiers for 2009 that will be used to describe the replacement of an entire device or a component of a device:
The RA modifier will be used to indicate the complete replacement of a device or component.

The RB modifier will be used to describe the replacement of a component of a device that is used as part of a larger repair.

AOPA is researching the appropriate use of these new modifiers and will provide additional information soon.

Nine new HCPCS codes will go into effect Jan. 1, 2009, including the following:
A-code that describes a compression garment used in the treatment of open venous stasis ulcers

E-code that describes a transcutaneous neurostimulation device

L-code that describes a prefabricated torticollis orthosis

six new terminal device codes that correct hierarchical code errors made in the 2008 HCPCS update.

Deleted Codes and Modifiers
As noted, CMS has replaced the RP modifier, which had indicated replacement of a device or component of a device, with either the RA or RB modifier, depending on the replacement scenario. Claims containing an RP modifier that are submitted after Dec. 31, 2008, will be denied.

CMS also has deleted L2860 and L3890, which describe concentric, adjustable, torsion-style orthotic joints for lower-extremity and upper-extremity use, respectively. While these codes were ruled invalid for Medicare submission several years ago, they are still used by providers when billing other insurers. The deletion of these codes will require the use of unlisted procedure codes to describe the function of these joints.

Also significant, the 2009 HCPCS deletes the heavy-duty feature codes (L5993, L5994, and L5995) for lower-extremity prostheses. These codes were previously used to describe additional features of prosthetic feet, knees, or other components that accommodate patients weighing more than 300 pounds. After Jan. 1, 2009, providers will be required to use the unlisted procedure code, L5999, to describe these additional features.

The remaining 2009 HCPCS code deletions involve the six terminal devices that were originally assigned codes that were outside the proper hierarchical code order.

In addition, the descriptor for L4360 has been changed to accommodate new technology in the design of walking boots. The words “and/or vacuum” have been added to the descriptor to accommodate technology that relies on the removal of air from a walker to achieve the same clinical results previously made possible solely through compression.