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Facet Joint Injections Considered for RAC Review

The recovery audit contractor (“RAC”) for Region B covering the Midwestern states, CGI Federal, Inc., is requesting additional documentation from providers regarding facet joint injections without reported imaging guidance (CPT codes 64470-64476). The requests for additional documentation acknowledge that CMS has not yet approved this issue for complex review and further acknowledge that the RAC Statement of Work mandates that no improper payments may be recovered until CMS approves the area for complex review. However, the RAC is requesting documentation to determine whether overpayments exist. If overpayments are identified, the claims will not be sent to the Medicare claims processor for adjustment unless and until CMS approves the topic of facet joint injections for complex review.

According to the RAC, the issue of facet joint injections was identified for review based upon the OIG report related to facet joint injections, the National Government Services, Inc. (“NGS”) local coverage determination (“LCD”) covering pain management, Coding and Compliance Focus News and an American Society of Anesthesiologists (“ASA”) Committee on Economics Memorandum.

For more information on this topic, please contact Abby Pendleton, Esq. or Jessica L. Gustafson, Esq. at (248) 996-8510 or visit the Anesthesia Page of The HLP website.

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