Modifiers

Reminder for Submission of Modifier 22

National Government Services would like to remind providers of the requirement for modifier 22. The Centers for Medicare & Medicaid Services (CMS) Internet-Only Manual (IOM) Publication 100-04, Medicare Claims Processing Manual, Chapter 12, Section 40.2, Part A, Item 10 (1 MB) lists the following requirements.

Unusual Circumstances

Surgeries for which services performed are significantly greater than usually required may be billed with modifier 22 added to the CPT code for the procedure. 

The biller must provide:

  • a concise statement about how the service differs from the usual service. This must be supported within the operative note.

Per the CMS IOM, you are required to provide a concise statement to support the modifier 22 on the service. Enter a concise description to justify the modifier 22 on the electronic notepad or Item 19 for providers eligible to file paper claims. Providers eligible for paper claims submission may also attach the report. Providers who participate in PWK may submit unsolicited medical records in addition to any comment they wish to add. Any reports supplied must clearly document the justification for the modifier 22.

Services submitted with modifier 22 that do not meet these requirements will not be considered for additional reimbursement and the service will price at the normal Medicare Fee Schedule rate with no additional allowance.

The concise statement and any submitted reports must support substantial additional work. It must clearly indicate and explain the difficulty of the procedure beyond the norm.

Vague phrases will not be considered supportive of an unusual circumstance requiring payment in excess of the Medicare Fee Schedule rate. Examples of unacceptable explanations include:   

    • Surgery took an extra two hours
    • This surgery was difficult
    • Surgery was for a morbidly obese patient
      • You must include supportive information for this. There are ICD-10 codes for the BMI ranges. Please provide this information if the difficulty in the procedure involved this. Only a BMI of 40+ is considered morbidly obese and may warrant additional payment with other corroborating clinician information in the operative note.
    • Surgery was harder/longer than average
    • Distorted anatomy (if due to revision and no revision code exists, please include this information)
    • Canned statements used repeatedly on multiple patients are not acceptable

If you receive a remittance advice and realize information to support this modifier was omitted, you must not resubmit the claim. You are required to follow the redetermination process.

Compliance with these instructions will help improve the timeliness and accuracy of claim payments.

Revised 12/8/2022