According to a recent investigation from the Office of Inspector General (OIG), the Centers for Medicare and Medicaid Services (CMS) overpaid nearly $26 million to hospitals between 2013 and 2015. While this is a huge sum for any field, this overpayment amount all came from a single category: claims for intensity modulated radiation therapy, or IMRT. By OIG’s estimate, the vast majority of this overpayment was due to unbundling, or separating services that were meant to be billed together.

Used mainly to treat tumors that are difficult to access by other means, IMRT is usually bundled into a single code, CPT 77301 (Intensity modulated radiotherapy plan, including dose-volume histograms for target and critical structure partial tolerance specifications). Unfortunately, virtually all of the studied claims also billed 77290 (Therapeutic radiology simulation-aided field setting; complex) even though the process of building a computer simulation is already included in 77301.

But 77290 isn’t the only code responsible. Below is a full list, courtesy of AAPC, detailing all services that are automatically included in 77301.

As a result of these massive overpayments, CMS has updated its guidance to read “Payment for the services identified by CPT codes 77014, 77280, 77285, 77290, 77295, 77306 through 77321, 77331, and 77370 are included in the APC payment for CPT code 77301 (IMRT planning). These codes should not be reported in addition to CPT code 77301 when provided prior to or as part of the development of the IMRT plan. In addition, CPT codes 77280-77290 (simulation-aided field settings) should not be reported for verification of the treatment field during a course of IMRT.”