Targeted Probe and Educate Topics

Jurisdiction 6 Part B Targeted Probe and Educate: Medical Review Topics

Topic CPT Code(s) Common Denials Resources
Incision and drainage of abscess (e.g., carbuncle, suppurative hidradenitis, cutaneous or subcutaneous abscess, cyst, furuncle, or paronychia); simple or single 10060 TBD Local Coverage Determination (LCD) L33563 – Incision and Drainage of Abscess of Skin, Subcutaneous and Accessory Structures
Incision and drainage of abscess (e.g., carbuncle, suppurative hidradenitis, cutaneous or subcutaneous abscess, cyst, furuncle, or paronychia); complicated or multiple 10061 TBD Local Coverage Determination (LCD) L33563 – Incision and Drainage of Abscess of Skin, Subcutaneous and Accessory Structures
Debridement, subcutaneous tissue (includes epidermis and dermis, if performed); First 20 sq cm or less 11042 A07 The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include some or all of the required medical necessity and/or documentation requirements such as (but not limited to):
    • An operative note or procedure note for the debridement service. This note should describe the anatomical location treated, the instruments used, anesthesia used if required, the type of tissue removed from the wound, the depth and area of the wound and the immediate post procedure care and follow-up instructions.
    • Identification of the wound location, size, depth and stage either by description and/or a drawing or photograph.
A65 Information requested from the provider was insufficient/incomplete.
  • Information received was for the incorrect beneficiary, date of service, or did not include the procedure report.
Local Coverage Determination (LCD) L33614 – Debridement Services

Title XVIII of the Social Security Act (SSA), Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Debridement, muscle and/or fascia (includes epidermis, dermis and subcutaneous tissue if performed); First 20 sq cm or less 11043 TBD Local Coverage Determination (LCD) L33614 - Debridement Services
Paring or Cutting of Benign Hyperkeratotic Lesion 11055, 11057 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include some or all the required elements including the necessary class findings, the presence of a qualifying systemic illness causing a peripheral neuropathy, and/or does not include precise and specific findings including specific location of lesion(s).
  • The documentation does not support the class findings modifier billed.
362 – The documentation does not support the medical necessity for the level of care billed. The reviewer recoded the service to a higher or lower level of care, depending on what the documentation supported.
Local Coverage Determination (LCD): L33636 – Routine Foot Care and Debridement of Nails

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 290

Title XVIII of the Social Security Act (SSA), Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Shaving of epidermal or dermal lesion, single lesion, face, ears, eyelids, nose, lips, mucous membrane; lesion diameter 0.6 to 1.0 cm 11311 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include a description of the lesion(s) indicating signs/symptoms which would support medical intervention.
  • The documentation does not support clinical uncertainty as to the likely diagnosis (skin tag), particularly where malignancy is a realistic consideration based on lesion appearance.
B65 – Services not furnished directly to the patient and/or not documented.
  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
Local Coverage Article A54602: Billing and Coding: Removal of Benign Skin Lesions

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 30

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 16, Sections 20 and 180

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Flap, trunk wound closure 15734 A98 – The documentation does not support the medical necessity of the service billed.
  • Review completed according to NGS Medical Directors
  • CPT 15734 should be included/bundled with another CPT, which was billed on the claim, and not separately billed.
  • The documentation does not support a flap was present and/or that a true flap was created.
B65 – Services not furnished directly to the patient and/or not documented.
  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 30

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Debridement of nails, any method; 6 or more 11721 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include precise and specific findings including specific nails that were debrided
  • The documentation does not specify which nails were debrided.
  • The documentation does not support a systemic disease, such as metabolic, neurologic, or peripheral vascular disease, of sufficient severity that performance of such services by a nonprofessional person would put the patient at risk.
  • The documentation does not support the class findings that were billed.
Local Coverage Determination (LCD): L33636 – Routine Foot Care and Debridement of Nails

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 30

Title XVIII of the SSA, Section 1833(e)
Debridement of nails, any method; six or more when billed with an E/M code with modifier 25 11721 and E/M code TBD Local Coverage Determination (LCD): L33636 - Routine Foot Care and Debridement of Nails

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 30

Title XVIII of the SSA, Section 1833 (e)
Destruction of Benign Lesions; up to 14 Lesions 17110 A98 – The documentation does not support the medical necessity of the service billed.
  • The documentation does not support that there were signs or symptoms present indicating the removal of the benign skin lesion(s).
  • The documentation submitted did not support that there were signs or symptoms present indicating the noncosmetic removal of the benign skin lesion(s). The submitted documentation supports that the removal of warts was cosmetic.
Billing and Coding Article: Removal of Benign Skin Lesions (A54602)
 

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 16, Section 20 and Section 180

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.6.2.2

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)

Total Knee Arthroplasty 27447 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not support if the joint disease is evidenced by conventional radiography, or MRI.
  • The documentation does not support unsuccessful nonsurgical medical management, when appropriate, and attempted for a minimum of 3 months. (When nonsurgical medical management is not appropriate, the medical record must clearly document the basis for that conclusion).
A65 – Information requested from the provider was insufficient/incomplete.
  • Information received was for the incorrect beneficiary, date of service, or did not include the procedure report.
Local Coverage Determination (LCD) L36039-Total Joint Arthroplasty

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.2.3.8(A) and (B)

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
 
Endovenous ablation therapy of incompetent vein, extremity, inclusive of all imaging guidance and monitoring, percutaneous, radiofrequency; first vein treated 36475 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include test results to confirm the presence and location of incompetent perforating veins; the level of incompetence of the vein(s) involved and/or documentation to support absence of thrombosis or vein tortuosity.
Local Coverage Determination (LCD) L33575-Varicose Veins of the Lower Extremity, Treatment of

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Extracapsular Cataract Removal 66984 A07 – The documentation does not support the medical necessity per policy guidelines. The documentation lacks one or more of the following requirements:
  • Cataract causing symptomatic impairment of visual function.
  • Impaired of visual function is not correctable with a tolerable change in glass or contact lenses.
  • Visual impairment resulting in specific activity limitation and/or participation restrictions.
  • Other eye disease(s) including, but not limited to, macular degeneration or diabetic retinopathy have been ruled out as the primary cause of decreased visual function.
A65 – Information requested from the provider was insufficient/incomplete.
  • Information received was for the incorrect beneficiary, date of service, or did not include the procedure report.
Local Coverage Determination (LCD) L33558-Cataract Extraction

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 260.2

CMS IOM Publication 100-03, Medicare National Coverage Determinations Manual, Chapter 1, Part 1, Sections 10.1 and 80

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.2.3.8(A) and (B)

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Ultrasound, Breast Complete 76641 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include an indication.
  • The breast ultrasound is being completed as supplemental screening with mammography for patients with dense breasts or a personal/family history of breast cancer.
  • The breast ultrasound must be diagnostic. Medicare does not pay for screening breast ultrasounds.
Local Coverage Determination (LCD) L33585-Breast Imaging: Breast Echography (Sonography)/Breast MRI/Ductography

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Psychiatric Diagnostic Evaluation 90791 A07 – The documentation does not support the medical necessity per policy guidelines. The documentation lacks one or more of the following requirements:
  • The treatment plan must state the type, amount, frequency, and duration of the duration of the services to be furnished and indicate the diagnoses and anticipated goals.
  • The psychiatric diagnostic procedure requires the elicitation of a complete medical (including past, family, social) and psychiatric history, a mental status examination, establishment of an initial diagnosis, an evaluation of the patient's ability and capacity to respond to treatment, and an initial plan of treatment.
  • Family history was not documented.
  • Information may be obtained from not only the patient, but also other physicians, healthcare providers, and/or family if the patient is unable to provide a complete history. If unable to obtain the history, attempts at obtaining must be documented.
B65 – Services not furnished directly to the patient and/or not documented.
  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
Local Coverage Determination (LCD) L33632-Psychiatry and Psychology Services

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 30

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Psychiatric Diagnostic Evaluation with Medical Services 90792 A07 – The documentation does not support the medical necessity per policy guidelines. The documentation lacks one or more of the following requirements:
  • The treatment plan must state the type, amount, frequency, and duration of the duration of the services to be furnished and indicate the diagnoses and anticipated goals.
  • The psychiatric diagnostic procedure requires the elicitation of a complete medical (including past, family, social) and psychiatric history, a mental status examination, establishment of an initial diagnosis, an evaluation of the patient's ability and capacity to respond to treatment, and an initial plan of treatment.
  • Family history was not documented.
  • Information may be obtained from not only the patient, but also other physicians, healthcare providers, and/or family if the patient is unable to provide a complete history. If unable to obtain the history, attempts at obtaining must be documented.
A65 – Information requested from the provider was insufficient/incomplete.
  • Information received was for the incorrect beneficiary, date of service, or did not include a visit note and/or treatment plan.
Local Coverage Determination (LCD) L33632-Psychiatry and Psychology Services

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.2.3.8(A) and (B)

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Psychotherapy, 60 minutes with patient 90837 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include an initial and/or updated individualized treatment plan that includes the type, amount, frequency, duration, diagnosis and anticipated goals.
  • The documentation does not include an encounter note that includes functional status, focused mental status exam, and progress to date.
  • The documentation does not support the correct billing of the telehealth visit.
  • The documentation does not include an updated treatment plan to support the continued need for prolonged services.
  • The documentation does not include specific time spent in Psychotherapy.
B65 – Services not furnished directly to the patient and/or not documented.
  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
  • Incident-to requirements were not met when services were provided by a nonphysician practitioner.
Local Coverage Determination (LCD) L33632-Psychiatry and Psychology Services

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 6, Section 70.1

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Sections 30 and 60.1-60.2

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Psychotherapy with E/M 90838 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not include an initial and/or updated individualized treatment plan that includes the type, amount, frequency, duration, diagnosis and anticipated goals.
  • The documentation does not include an encounter note that includes functional status, focused mental status exam, and progress to date.
  • The documentation does not include an updated treatment plan to support the continued need for prolonged services.
  • The documentation does not include specific time spent in Psychotherapy.
  • The documentation does not support the correct billing of the telehealth visit.
  • The submitted provider notes were not authenticated.
Local Coverage Determination (LCD) L33632-Psychiatry and Psychology Services

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Sections 30 and 60.1-60.2

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 12, Section 190

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.3.2.4

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A))

Duplex scan of extremity veins – bilateral

93970

A07 – The documentation does not support the medical necessity per policy guidelines.

  • The documentation lacked a relevant medical history, physical exam, and/or a progress note or other assessment of the patient from a treating provider that clearly supports the clinical need for the study on the billed date of service.
  • The documentation was missing an order/intent to order for the study.
  • The documentation did not support the provider performing and/or interpreting the study possessed the appropriate credentialing and accreditation requirements.

362 – The documentation does not support the medical necessity for the level of care billed. The documentation supported the medical necessity for a unilateral study; therefore, the claim was recoded to a lower level of care.

Local Coverage Determination (LCD) L33627 – Non-Invasive Vascular Studies

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 80

Title XVIII of the Social Security Act (SSA), Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)

Duplex scan of extremity veins - unilateral or limited study 93971

A07 – The documentation does not support the medical necessity per policy guidelines.

  • The documentation lacked a relevant medical history, physical exam, and/or a progress note or other assessment of the patient from a treating provider that clearly supports the clinical need for the study on the billed date of service.
  • The documentation was missing an order/intent to order for the study.
  • The documentation did not support the provider performing and/or interpreting the study possessed the appropriate credentialing and accreditation requirements.

Local Coverage Determination (LCD) L33627 – Non-Invasive Vascular Studies

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 80

Title XVIII of the Social Security Act (SSA), Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)

Health behavior assessment, or re-assessment 96156 A98 – The documentation does not support the medical necessity of the service billed.
  • The documentation does not include a complete assessment including a complete mental status exam, goals and/or expected duration of specific interventions.
B65 – Services not furnished directly to the patient and/or not documented.
  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
Local Coverage Article (LCA) A52434-Health and Behavior Assessment/Intervention

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Sections 30 and 160

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 12, Sections 170.0 and 170.1 190

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A))
Debridement, Open Wound, first 20 square cm or less 97597 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation failed to support one or more of the following: An operative note or procedure note for the debridement service which includes the anatomical location treated, the instrument(s) used, anesthesia used if required, the type of tissue removed from the wound, the depth and area of the wound and the immediate post procedure care and follow-up instructions.
Local Coverage Determination (LCD) L33614-Debridement Services
Initial Hospital Inpatient or Observation Care, per Day, High Level of Medical Decision Making, Typically 75 Minutes, or More 99223

118 – The documentation does not support the medical necessity for the level of care billed. The reviewer recoded the service to a higher or lower level of care, depending on what the documentation supported.

B65 - Services not furnished directly to the patient and/or not documented.

  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.

A98 – The documentation does not support the medical necessity of the service billed.

  • Documentation does not support a split/shared service was performed
  • Billed modifiers should be supported in the documentation

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 30 and 60

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 12, Section 30.6 and 100.11

2023 CPT E/M Descriptors and Guidelines

Evaluation & Management Visits

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)

 

Ambulance service, advanced life support, emergency transport, level 1 (ALS 1-emergency) A0427

A98 – The documentation does not support the medical necessity of the service billed.

  • The documentation submitted lacks evidence to support emergent, Advanced Life Support Service.
  • The documented miles do not equal billed miles.
  • The documentation does not support that the more distant facility was the appropriate facility to provide the necessary care.

A65 – Information requested from the provider was insufficient/incomplete.

  • Missing, Illegible and/or incomplete signature(s).
  • The documentation submitted does not include the beneficiary and/or beneficiary representative’s signature and is insufficient to support the authorization of assignment of benefits.

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 10

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 15

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.3.2.4

42 Code of Federal Regulations (CFR) Section 424.36

Title XVIII of the Social Security Act (SSA), Section 1833(e)

Title XVIII of the SSA, Section 1861(s)(7)

Title XVIII of the SSA, Section 1862(a)(1)(A)

Beovu (brolucizumab) with Intravitreal injection of a pharmacologic agent J0179 and 67028 All reviewed claims have been paid/allowed. The primary reason for claims being denied under this review is due to nonresponse to the ADR by the provider. Please view the links below for the ADR information and tips for best practices.
Botox (onabotulinum toxin A) J0585 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation is missing dosage given per site.
  • The documentation is missing a covered indication for the Botox to be given more than every 12 weeks.
  • The documentation does not include a history of the chronic headaches, nor does it identify or link a specific significant disability caused by the headaches, all of which is needed to support the initiation of the treatment.
  • The documentation does not support a significant decrease in the number and frequency of headaches and an improvement in function upon receiving the injections.
  • The documentation does not include the current number of headache days the patient is experiencing. Documentation should include current information on headaches.
  • Evidence of conservative treatment tried and proven unsuccessful should be documented.
  • Frequent cloned documentation.
Local Coverage Determination (LCD) L33646-Botulinum Toxins

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.6.2.2

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)
Immune globulin (gammagard liquid), non-lyophilized, 500 mg J1569 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not support the medical necessity for the administration of IVIG.
  • The documentation did not include some or all the required elements based on the diagnosis.
B65 – Services not furnished directly to the patient and/or not documented.
  • The documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
Local Coverage Determination (LCD) L33394- Drugs and Biologicals, Coverage of, for Label and Off-Label Uses

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Sections 30

Title XVIII of the SSA, Section 1833(e)
Lucentis(ranibizumab) with Intravitreal injection of a pharmacologic agent J2778 with 67208 All reviewed claims have been paid/allowed. The primary reason for claims being denied under this review is due to nonresponse to the ADR by the provider. Please view the links below for the ADR information and tips for best practices.
Hyaluronan or derivative, Gel-One or Monovisc, for intra-articular injection and arthrocentesis, aspiration and/or injection, major joint or bursa with or without ultrasound guidance J7326, J7327 A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not support improvement of functional capacity for subsequent injections.
  • The documentation does not include subjective patient report of knee pain at the time of injection.
  • The documentation was missing one or more of the following: a diagnosis and/or history of symptomatic osteoarthritis of the knee, radiologic evidence to support osteoarthritis diagnosis, and documentation to support failure of at least three months of conservative treatment
A69 - The documentation does not include a valid, legible identifier for the services provided and no response was received in response to our Signature Attestation request that was sent.
  • Medicare requires a valid, legible handwritten or electronic signature for all documentation.
B65 - Services not furnished directly to the patient and/or not documented.
  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
Local Coverage Determination (LCD) L33394: Drugs and Biologicals, Coverage of, for Label and Off-Label Uses

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3, Section 3.6.2.2

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A)

MLN® Fact Sheet: Complying with Medicare Signature Requirements
Outpatient Physical Therapy, Occupational Therapy, and/or Speech Language Pathology All therapy codes when billed with KX modifier A07 – The documentation does not support the medical necessity per policy guidelines.
  • The documentation does not support the approval/certification of the POC for the therapy services and/or POC submitted was signed by a medical assistant and not signed by a physician/ nonphysician practitioner.
  • The documentation does not indicate the amount and type of assistance required by the therapist for the beneficiary to complete the treatments, and/or did not support that the level of complexity or condition of the patient required the services that could only be performed safely and effectively by a qualified therapist.
  • The documentation lacked the requirements to support the medical necessity of the additional services beyond the therapy threshold and/or lacked justification to support the need for additional therapy and how the additional therapy would directly and significantly impact the rate of recovery of the condition being treated such that it is appropriate to exceed the threshold and/or lacked evidence to support the ongoing skills of a qualified therapist were required to complete the treatment.
B65 - Services not furnished directly to the patient and/or not documented.
  • The submitted documentation does not support that the rendering provider of the service is the billing provider reported on the claim.
Local Coverage Determination (LCD): Outpatient Physical and Occupational Therapy Services (L33631)

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Sections 30, 220

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 5, Section 10.3.2-10.3.3

CMS IOM Publication 100- 08, Medicare Program Integrity Manual, Chapter 3, Sections 3.4.1.3, 3.6.2.1, 3.6.2.2

Title XVIII of the SSA, Section 1833(e)

Title XVIII of the SSA, Section 1862(a)(1)(A) 42 Code of Federal Regulations (CFR) Sections 409.17, 409.44, 410.60, 410.61(a) and (c)

 


*Not an all-inclusive list of resources

If a nonresponse to an ADR occurs, the claim may deny with denial code 692. A 692 denial will negatively impact a provider's error rate and may result in additional rounds of TPE review. By implementing TPE best practices and responding to ADRs, this is an easily preventable denial.

Additional References

Revised 4/15/2024