RECELL® Reimbursement Frequently Asked Questions
Looking for information? Choose from the list below for answers to commonly asked questions about RECELL reimbursement.
- Effective October 1, 2019, CMS issued new ICD-10 procedure code 0HR_X72 Skin replacement on the ___, autologous tissue substitute, cell suspension technique where “___” specifies the body part to which the graft is applied, e.g., 7-Skin, Abdomen, 8-Skin, Buttock, J-Skin, Left Upper Leg, etc. RECELL System is uniquely identified by assignment of qualifier 2 (last digit) for the application of a cell suspension autograft.1, 2
- Inpatient hospital payments vary depending on the patient diagnoses which determine the Diagnostic Related Group (DRG) from which the hospital stay is paid.
- Yes, CMS recommends the use of code 0HB_XZZ Excision of skin and breast, skin where “_” specifies the body part from which the skin sample is taken, e.g., 7-Skin, Abdomen, 8-Skin, Buttock, J-Skin, Left Upper Leg, etc.2, 3
- The small, harvested skin sample is sometimes referred to as a “biopsy” in the operative report although in this case, the sample is for therapeutic rather than diagnostic use.
- For physician services using the RECELL System, the American Burn Association (ABA) recommends epidermal autograft codes for the application of cell suspension autografts, e.g., RECELL.4
- Payments for physician services are typically determined by each payer’s fee schedule amounts for the provided services.
- The Centers for Medicare and Medicaid Services (CMS) created a new technology Transitional Pass-through (TPT) Payment C-code for reporting RECELL® devices when used in procedures performed in the hospital outpatient department and ambulatory surgery center (ASC) settings on or after January 1, 2022.5
- The new C-code is:
C1832 Autograft suspension, including cell processing and application, and all system components5
- Medicare Transitional Pass-through status is intended to temporarily provide payment for the new devices while collecting data to support the establishment of a permanent payment mechanism at the end of the 2-3-year transitional period.
- Devices that are eligible for TPT status demonstrate substantial clinical improvement, are new and meet specific cost criteria.
- TPT payments are made to hospital outpatient facilities or ambulatory surgical centers (ASC).
- The payment amount for the new C-code varies by facility due to different mark-up practices at each hospital.
- Outpatient hospital department payment is based on charges reduced to cost.
- ASC payment is determined by the Medicare contractor.
- FDA approval is specific to the indication, and therefore is independent of place of service. The appropriate place of service is a physician decision.
- The new outpatient facility C-code for the RECELL System is specifically for use in hospital outpatient department and ambulatory surgery center (ASC) places of service.
- The Place of Service (POS) code used on the claim form confirms facility type for reimbursement purposes.
- Hospital outpatient department, off-campus (POS code=19)
- Hospital outpatient department, on-campus (POS code=22)
- Ambulatory surgical center (POS code=24)
- The new C-code is Medicare-specific. Some commercial payers may provide reimbursement for Medicare codes.
- This C-code is a Medicare-specific code for specific outpatient settings (hospital outpatient departments and ambulatory surgery centers). While commercial payers frequently adopt Medicare codes, there are no guarantees that commercial payers will cover and pay hospitals or ASCs for this code.
- AVITA Medical will work to expand the number of commercial payers that will cover and pay facilities for these codes.
- No, this code is for outpatient facilities to report RECELL devices used in outpatient procedures.
- Surgeons should follow guidance from the Coding Committee of the American Burn Association (ABA) in September 2018 for reporting RECELL procedures.4
- The RECELL Access Program produces RECELL reimbursement materials and provides support for pre-authorizations, appeals and other reimbursement inquiries.
- The RECELL Access Program can be reached by phone (833-674-1688) or by email ([email protected]).
- Hospital Inpatient Prospective Payment System for FY 2020 (Final Rule). Federal Register, Vol. 84, No. 159,August 16, 2019, and Vol. 84, No. 195, October 8, 2019. https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/FY2020-IPPS-Final-Rule-Home-Page. Accessed April 29, 2022.
- Centers for Medicare & Medicaid Services. 2022 ICD-10-PCS Code Tables and Index. https://www.cms.gov/medicare/icd-10/2022-icd-10-pcs. Accessed April 29, 2022.
- Centers for Medicare & Medicaid Services. ICD-10 Coordination and Maintenance Committee Meeting Agenda. September 11, 2018. Accessed April 29, 2022.
- American Burn Association. Cell Suspension Autograft CPT Coding Recommendation. http://ameriburn.org/cell-suspension-autograft-cpt-coding-recommendation/. Accessed April 29, 2022.
- Centers for Medicare & Medicaid Services. Hospital Outpatient Prospective Payment System for CY 2022 (Final Rule). 86 Fed. 218, November 16, 2021. https://www.cms.gov/medicaremedicare-fee-service-paymenthospitaloutpatientpps/cms-1753-fc. Accessed April 29, 2022.