CMS: Expedite 'Crosswalking' to Prevent Coding Hassles
By Michael J. Allen, CPO, FAAOP  In 1996, Congress enacted the Health Insurance Portability and Accountability Act, commonly known as HIPAA. One of the many requirements of HIPAA is the standardization of Healthcare Common Procedure Coding System (HCPCS) codes. All providers and suppliers are reimbursed from Medicare and Medicaid by assigning a particular HCPCS code to a specific professional service, device or supply item.
National Codes
Currently, the Centers for Medicare and Medicaid Services (CMS) recognizes the HCPCS coding system, consisting of three levels of codes. Level I is the American Medical Association (AMA) Current Procedural Terminology (CPT) codes that describe certain medical and ancillary procedures. Level II is CMS' national set of procedural codes that describe durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) and certain other procedures/services. Level III refers to locally developed codes, which have been generated and maintained by some state Medicaid carriers.
In accordance with HIPAA, all Level III HCPCS codes will be eliminated by October 2003. This presents both an opportunity and a challenge for those states that currently have access to Level III O&P codes.
Provider Coalition
The National Association for the Advancement of Orthotics and Prosthetics (NAAOP) is working closely with a coalition of other health care provider and supplier organizations to urge CMS to prioritize their efforts in complying with legislative mandates. NAAOP has met with representatives of CMS to discuss CMS' current efforts to crosswalk local Medicaid codes for DMEPOS and strategies to ensure the success of the crosswalking project.
The coalition has emphasized the importance of stepping up current measures to crosswalk codes in order to avert significant disruptions to O&P practitioners when local DMEPOS codes are phased out in the future.
The process for obtaining new codes is long and cumbersome and normally occurs once each year. If CMS does not increase its efforts to complete the crosswalking project in time, then it will have to develop a more streamlined process for creating new national codes. Otherwise applications for new Level II codes to replace the Level III codes that become unavailable in October 2003 will not even be submitted until April 2004.
A Crisis in the Making?
Unless the crosswalk project is completed, some practitioners will be unable to submit an appropriate code for services they now provide. If a proper Level II code does not exist, the provider will be forced to choose an inappropriate code or face the uncertainties associated with miscellaneous codes (Lxx99).
A case in point: In Texas, 34 Level III codes were left out of CMS' data collection. Unless these codes are properly crosswalked and new Level II codes established, O&P practitioners will lose access to codes describing various orthotic procedures and additions, e.g., supramalleolar orthoses, instep straps, inhibitive designs, etc.
NAAOP has strongly urged CMS to step up its efforts and devote more resources to identify and crosswalk all O&P Level III codes. If not, a potential coding crisis will occur for O&P practitioners who use local codes to describe pediatric or other specialty procedures.
Your Help is Needed
NAAOP is working closely with the American Academy of Orthotists and Prosthetists (AAOP) to identify states affected by CMS' action and inaction. If you believe you will be affected by the crosswalk project, you are encouraged to contact NAAOP, the Academy, or your state's association or Academy chapter.
Michael J. Allen, CPO, FAAOP, is President of NAAOP. Additional information regarding NAAOP's legislative activities may be found at
www.oandp.com/naaop 
Table Of Contents - July 2002
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