By Marta Van Beek, MD, MPH
Marketing of new technology for superficial radiationtherapy (SRT) devices and electronic surface brachytherapy (eBx) devices to dermatologists has increased in the past year.
These devices are being marketed as highly effective treatments for cutaneous basal cell carcinomas (BCC) and squamous cell carcinomas (SCC). In some circumstances, they have also been positioned as devices with the potential to drive significant revenue growth. As a result, use of CPT codes related to these services has rapidly increased.
On Nov. 9, the Academy’s Board of Directors approved position statements on SRT and eBx for BCC and SCC. The Academy’s Radiation Therapy Workgroup developed the position statement to address a number of issues arising from these two technologies, including multiple coding and reimbursement concerns, regulatory issues on the delivery of these technologies that vary from state to state, and the limited amount of research on the long-term efficacy of these two new technologies.
Inaccurate coding of these services may expose a practitioner to increased payer scrutiny and audits.
The Academy supports surgical treatment as the optimal primary intervention for BCC and SCC. In circumstances when surgical intervention is contraindicated, the Academy supports the provision of superficial radiation therapy or electronic surface brachytherapy as a treatment option for these carcinomas.
Aggressive marketing of the devices, however, has given rise to concerns about some claims made about SRT and eBx products. It has come to the Academy’s attention that inaccurate information about coding and reimbursement, as well as efficacy, may be included in promotional materials.
We believe that several vendors have been advising dermatologists to report CPT codes that do not accurately reflect the services provided, which may result in misrepresentation of the service provided and trigger payer audits.
Consequently, certain codes are being utilized by dermatologists in a disproportionate manner as they relate to SRT and eBx. In accordance with coding conventions and guidelines, the AADA wants to emphasize that dermatologists should only bill for services that they actually provide.
The appropriate CPT code for skin treatment in the SRT modality is 77401. This code is reported only once per session and not per lesion, regardless of how many locations on the body are treated during the encounter. Codes 77402, 77407, and 77412 are not appropriate for dermatologists to report for treatment of skin lesions with SRT. Check with your local carriers for other coding guidance specific to reporting such services.
Dermatologists can appropriately report eBx treatment with code 0182T. The eBx technology was originally developed by radiation oncologists for breast and endometrial applications. A significant number of states have regulations that limit administration of eBx to only those physicians who are trained as radiation oncologists. Inaccurate coding of these services may expose a practitioner to increased payer scrutiny and audits.
Regulatory and business issues
Many states have regulations regarding education and training requirements to administer these services, and other states are actively investigating or enacting rules around these devices. A number of states also limit the provision of eBx to radiation oncologists.
Business models associated with the provision of these services may be considered self-referral. Self-referral arrangements are under increasing scrutiny by the Government Accountability Office and other watchdog groups.
More research is needed
More research is needed to document the long-term efficacy of these new SRT and eBx devices. There are many published articles documenting the benefit of radiation for a variety of dermatologic diseases, but these specific technologies are new and distinct from historical methods of delivering radiation or brachytherapy.
The AADA position statement is meant to encourage member education and awareness about state and federal regulations, proper coding to avoid potential payer scrutiny and audits, and appropriate business models to protect us from violating self-referral laws.
Dr. Van Beek is clinical associate professor of dermatology at the University of Iowa Carver College of Medicine. She is chair of the AADA Council on Government Affairs, Health Policy, and Practice, and a member of the Radiation Therapy Workgroup.
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