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|141 Northwest Point Blvd | |

|Elk Grove Village, IL 60007-1019 |March 3, 2012 |

|Phone: 847/434-4000 | |

|Fax: 847/434-8000 |To Whom It May Concern: |

|E-mail: kidsdocs@ | |

| |I am writing on behalf of the 60,000 members of the American Academy of Pediatrics to object to your practice of inappropriately |

|Executive Committee |bundling certain procedures when they are reported on the same day as a global neonatal critical care code (99468-99469). |

|President | |

|Robert W. Block, MD, FAAP |Issue #1: Procedures Performed in the Delivery Room |

|President-Elect |While the neonatal critical care codes bundle commonly performed services such as endotracheal intubation (31500) and umbilical |

|Thomas K. McInerny, MD, FAAP |venous catheterization (36510), it is appropriate to report such procedures separately from 99468 (initial neonatal critical care, |

|Immediate Past President |per day, for the evaluation and management of a critically ill neonate, 28 days of age or younger) when they are performed as a |

|O. Marion Burton, MD, FAAP |necessary component of the pre-admission delivery room care. CPT guidelines state that “other procedures performed as a necessary |

|Executive Director/CEO |part of the resuscitation (eg, endotracheal intubation [31500]) are also reported separately when performed as part of the |

|Errol R. Alden, MD, FAAP |pre-admission delivery room care (CPT 2012, AMA Professional Edition, page 39) from the initial day neonatal critical care code. |

|Board of Directors | |

|District I |Some carriers attempt to limit reimbursement by incorrectly interpreting the neonatal critical care CPT guidelines. The National |

|Carole E. Allen, MD, FAAP |Correct Coding Initiative (NCCI) Edits specifically allow the reporting of any of the neonatal critical care codes with any of their |

|Arlington, MA |bundled procedures as long as the appropriate modifier is appended. For example, during neonatal resuscitation or as part of airway |

|District II |suctioning for meconium, an endotracheal intubation (31500) may be indicated. Since delivery room care and management is considered |

|Danielle Laraque, MD, FAAP |“pre-admission,” the procedures performed during that period of service in the delivery room are not considered bundled into the |

|Brooklyn, NY |neonatal critical care codes that commence only after the nursery admission, even if they are reported on the same calendar day. In |

|District III |this situation, code 31500 should be appended with the modifier 59 (distinct procedural service), indicating that in this particular |

|Sandra Gibson Hassink, MD, FAAP |situation it is a separate service from 99468. |

|Wilmington, DE | |

|District IV |Issue #2: Evaluation and Management Services Provided in the Delivery Room |

|Francis E. Rushton, Jr, MD, FAAP |Since the inception of the neonatal critical care codes, it has always been appropriate to report attendance at delivery (99464) or |

|Beaufort, SC |newborn resuscitation (99465) evaluation and management (E/M) codes in addition to the initial day neonatal critical care code |

|District V |(99468). Recently, certain carriers have started to inappropriately bundle 99464 or 99465 with 99468. CPT guidelines state that “the |

|Marilyn J. Bull, MD, FAAP |initial day neonatal critical care code can be used in addition to 99464 or 99465 as appropriate, when the physician is present for |

|Indianapolis, IN |the delivery (99464) or resuscitation (99465) is required.” (CPT 2012, AMA Professional Edition, page 39). Further, there are no NCCI|

|District VI |Edits on the reporting of 99464 or 99465 with 99468. This indicates that Medicare payment policy does not require the appending of a |

|Michael V. Severson, MD, FAAP |modifier to allow reimbursement for both services. |

|Shakopee, MN | |

|District VII |I urge you to reconsider your position on this issue. Thank you. |

|Kenneth E. Matthews, MD, FAAP | |

|College Station, TX |Sincerely, |

|District VIII |Margie Andreae, MD, FAAP |

|Kyle Yasuda, MD, FAAP |AAP Committee on Coding and Nomenclature |

|Seattle, WA | |

|District IX | |

|Myles B. Abbott, MD, FAAP | |

|Berkeley, CA | |

|District X | |

|Sara H. Goza, MD, FAAP | |

|Fayetteville, GA | |

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