Bundling

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www.aap.org
Executive Committee
January 1, 2014
Dear Medical Director:
I would like to clarify the fact that CPT guidelines indicate that services that are
identified with specific codes should be reported separately from any other code
and, therefore, they should not be “bundled” into any other code(s). This concept
is found throughout CPT guidelines. Some examples include:

Preventive Medicine Services: “Immunizations and ancillary studies
involving laboratory, radiology, other procedures, or screening tests
identified with a specific CPT code are reported separately” (CPT 2014
{professional edition}, page 34).

Vision Screening: “Other identifiable services unrelated to this screening
test provided at the same time may be reported separately [eg, preventive
medicine services]” (CPT 2014, {professional edition}, page 536).

Modifier 25: “It may be necessary to indicate that on the day a procedure or
service identified by a CPT code was performed, the patient’s condition
required a significant and separately identifiable E/M service above and
beyond the other service provided or beyond the usual preoperative and
postoperative care associated with the procedure that was performed. A
significant, separately identifiable E/M service is defined or substantiated
by documentation that satisfies the relevant criteria for the respective E/M
service to be reported.” (CPT 2014 {professional edition}, page 645) and “If
an abnormality/ies is encountered or a preexisting problem is addressed in
the process of performing this preventive medicine evaluation and
management service, and if the problem/abnormality is significant enough
to require additional work to perform the key components of a problemoriented E/M service, then the appropriate Office/Outpatient code 9920199215 should also be reported. Modifier 25 should be appended to the
Office/Outpatient code to indicate that a significant, separately identifiable
E/M service was provided by the same physician on the same day as the
preventive medicine service. The appropriate preventive medicine service is
additionally reported.” (CPT 2012 {professional edition}, page 34).
President
James M. Perrin, MD, FAAP
President-Elect
Sandra G. Hassink, MD, FAAP
Immediate Past President
Thomas K. McInerny, MD, FAAP
Executive Director/CEO
Errol R. Alden, MD, FAAP
Board of Directors
District I
Carole E. Allen, MD, FAAP
Arlington, MA
District II
Danielle Laraque, MD, FAAP
Brooklyn, NY
District III
David I. Bromberg, MD, FAAP
Frederick, MD
District IV
Jane M. Foy, MD, FAAP
Winston Salem, NC
District V
Marilyn J. Bull, MD, FAAP
Indianapolis, IN
District VI
Pamela K. Shaw, MD, FAAP
Kansas City, KS
District VII
Anthony D. Johnson, MD, FAAP
Little Rock, AR
District VIII
Kyle Yasuda, MD, FAAP
Seattle, WA
District IX
Stuart A. Cohen, MD, MPH, FAAP
San Diego, CA
District X
Sara H. Goza, MD, FAAP
Fayetteville, GA
Unfortunately, many carriers are unaware that they are violating CPT guidelines
when they inappropriately bundle two services together when each of the involved
services has a separate CPT code.
The aforementioned CPT guidelines are applicable to any other screening tests or
procedures that are identified with a specific CPT code, such as audiometry,
intramuscular injection of antibiotics, immunization administration, urinalysis or
cerumen removal. Therefore, physicians are correct in reporting such services
separately from any accompanying evaluation and management service. While
there is no legal mandate requiring private carriers to adhere to CPT guidelines, it
is considered a ‘good faith’ gesture for them to do so, given that the guidelines are
the current standard within organized medicine. Those separately reportable
services that are not recognized by a carrier should be designated non-covered
benefits and billable to the patient.
If you have any questions, please feel free to contact Becky Dolan, Health Policy Analyst,
Division of Health Care Finance & Quality Improvement at 800/433-9016 x4325 or
bdolan@aap.org . Thank you.
Sincerely,
Margie Andreae, MD, FAAP
Margie Andreae, MD, FAAP
Chair, Committee on Coding and Nomenclature
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