The American College of Mohs Surgery (ACMS) has issued letters to the Centers for Medicare and Medicaid (CMS) and Medicare Administrative Contractor (MAC), Palmetto, regarding the inappropriate use of image guidance and simulation with Superficial Radiation Therapy (SRT).

The letter to CMS supports NCCI edits that restrict the billing of daily ultrasonic guidance (HCPCS code G6001) and daily simulations (CPT code 77280) in combination with SRT (CPT code 77401) treatments. ACMS urges CMS to revise the Correct Code Modifier Indicator (CCMI) from ‘1’ to ‘0’ which would disallow reporting of these code pairs. This aligns with the sign-on letter that ASTRO recently sent to CMS.

The letter to Palmetto is in response to the proposed Local Coverage Determination (LCD) on SRT for treatment of Nonmelanoma Skin Cancers (NMSCs). In the letter, ACMS supports the restriction on the use of ultrasound and simulation with SRT. ASTRO has also urged Palmetto to finalize the proposed LCD and hopes that the effort will encourage other MACs to follow suit.