by Christine Woolstenhulme, QMC QCC CMCS CPC CMRS
Jan 28th, 2015 - Reviewed/Updated Aug 9th
Definition
- Separate Structure, A Service That Is Distinct Because It Was Performed on A Separate Organ/Structure
Appropriate Usage
- Coding pairs are part of the National Correct Coding Initiative (NCCI) procedure to procedure edits
- Documentation indicates the services were provided on different organs/structures
- Use Modifier XS with the Column 2 procedure code in the NCCI files
- Use Modifier XS only when there is no other modifier to describe the situation
Inappropriate Usage
- Code pairs are not part of the NCCI procedure to procedure edits
- If another valid modifier exists to identify the separate services
- Submission of E/M Codes
- Submission of Weekly radiation therapy management codes (CPT 77427)
- The NCCI code files show the modifier application as "0"
- Documentation does not support the services were provided on a separate organ/structure
- For example, both procedures were performed on the liver during a single encounter
- Exact same procedure code performed twice on the same day
- Multiple administration of injections of the same drug
- Submitted with Modifier 59
Additional Information
- NCCI listings can be found on the CMS Website
- Medicare considers two physicians in the same group with the same specialty performing services on the same day the same physician.
- Providers should evaluate other modifiers such as the RT/LT identifying right and left, F1 - F0 to identify fingers, T1-T0 to identify toes and E1-E4 to identify eyelids. Evaluate additional modifiers to determine appropriate usage.
References/Resources
About Christine Woolstenhulme, QMC QCC CMCS CPC CMRS
Christine Woolstenhulme, CPC, QCC, CMCS, CMRS, is a Certified coder and Medical Biller currently employed with Find-A-Code. Bringing over 30 years of insight, business knowledge, and innovation to the healthcare industry. Establishing a successful Medical Billing Company from 1994 to 2015, during this time, Christine has had the opportunity to learn all aspects of revenue cycle management while working with independent practitioners and in clinic settings. Christine was a VAR for AltaPoint EHR software sales, along with management positions and medical practice consulting. Understanding the complete patient engagement cycle and developing efficient processes to coordinate teams ensuring best practice standards in healthcare. Working with payers on coding and interpreting ACA policies according to state benchmarks and insurance filings and implementing company procedures and policies to coordinate teams and payer benefits.