How the NCCI Works
The Centers for Medicare & Medicaid Services (CMS) created the NCCI to act as a set of coding guidelines that inform the provider what codes can and cannot be billed together relative to a particular case or operative session. In other words, the NCCI sets forth what codes are bundled into other codes so that they cannot be separately billed.
As many of you know, NCCI edits are updated quarterly and consist of code pairs that are arranged in two columns (Column 1 and Column 2). Generally, codes listed in Column 2 are not payable if performed on the same day on the same patient by the same provider as a code listed in Column 1—unless the edits permit the use of a modifier, such as modifier 59 (distinct procedural service), to override the edits.
Next to Columns 1 and 2 is another column that contains a numerical code indicating whether or not a modifier can be used to override the edit. A "0" indicator means that you cannot unbundle the two codes under any circumstances. An indicator of "1" means that you may use a modifier to override the edit, but only if the clinical circumstances warrant separate payment and the documentation supports the description of the modifier applied.
In the following link, you can see the new edits that show the anesthesia and block codes that the NCCI now indicates you cannot bill separately: https://www.asahq.org/-/media/sites/asahq/files/public/advocacy/alerts/washington-alerts/ncci-edits_july-1-2025_asa.xlsx.
As you can see in the link, the NCCI indicates, by using the “0” indicator, that you may NOT override the edit, using the 59 or other modifier, when the code in column 2 is used with a code in column 1. This means that the block, in such combination, is not separately billable.
The Codes in Question
Based on the anesthesia codes listed in the above link, the bundling of the above listed block codes involve the following anatomical structures/procedures:
- Partial rib resection (00470-00474) does not allow bilateral single or continuous thoracic fascial plane block
- Esophagus and closed chest procedures (00500-00529) does not allow bilateral single or continuous thoracic fascial plane block
- Tracheobronchial reconstruction (00539) does not allow bilateral single or continuous thoracic fascial plane block
- Thoracotomy (00540-00548) does not allow bilateral single or continuous thoracic fascial plane block
- Sternal debridement (00550) does not allow unilateral or bilateral single or continuous thoracic fascial plane block
- Heart procedures (00560-00580) does not allow bilateral single or continuous thoracic fascial plane block
- Thoracic spine and cord (00620-00626) does not allow bilateral single or continuous thoracic fascial plane block
- Body cast application or revision (01130) does not allow unilateral or bilateral single or continuous thoracic fascial plane block
- Organ harvesting (01990) does not allow unilateral single or continuous thoracic fascial plane block
So, this is further evidence that Medicare seems content to whittle away at anesthesia reimbursement, including through these most recent bundling rules, which became effective July 1, 2025. Keep in mind that, while the NCCI is a Medicare creation, there are other payers—including commercial payers—that also adhere to the NCCI edits.
As one can imagine, the American Society of Anesthesiologists (ASA) was none too pleased about these July 1 edits and has registered its complaint with the NCCI contractor. The ASA website stated:
The current edits inappropriately prohibit the billing of the new fascial plane block codes (64466- 64489) when paired with certain surgical procedures. For example, the edit limits the use of the anesthesia codes for sternal debridement codes when paired with the unilateral thoracic fascial plane block code. Many other bilateral cardiac codes are also being impacted by this edit.
The ASA has requested these edits be reconsidered and removed and is actively working with CMS to get the issue resolved. Our readers may want to add their voices to the ASA’s by contacting the NCCI medical director at NCCIPTPMUE@cms.hhs.gov.