In Case You Missed It: CMS Reverses Decision on CPT Code 76937 for Ultrasound Guidance for Vascular Access

In Case You Missed It: CMS Reverses Decision on CPT Code 76937 for Ultrasound Guidance for Vascular Access

This year, the Centers for Medicare and Medicaid Services (CMS) updated the 2024 National Correct Coding Initiative (NCCI) Policy Manual to include CPT code 76937 in Chapter 9 (Section H, General Policy Statements):

“Radiological supervision and interpretation codes include all radiological services necessary to complete the service. Current Procedural Terminology® (CPT®) codes for fluoroscopy/fluoroscopic guidance (e.g., 76000, 77002, 77003) or ultrasound/ultrasound guidance (e.g., 76942, 76998, 76937) shall not be reported separately” (2024 NCCI Policy Manual).

Following an evaluation of feedback and input from various specialty societies, CMS made the decision to reverse its previous ruling and eliminate CPT code 76937. This change will be incorporated into the 2025 policy manual, as CMS revises the NCCI Policy Manual once annually.

The 2024 NCCI policy manual did not introduce any new or proposed procedure-to-procedure edits for CPT code 76937. Therefore, radiology practices should still use code 76937 when it’s carried out and properly documented with other procedures, such as embolization, selected catheter placement, or dialysis circuit access. For further coding guidance, consult the 2024 CPT code book.

Our Commentary on the CMS Reversal of CPT Code 76937

This modification would have precluded the reporting of code 76937 for nearly all Interventional Radiology services, such as CVAD procedures, angioplasty, stenting, angiograms/venograms, etc. Following significant appeals from numerous societies and providers, CMS announced on February 14, 2024, that the change has been reversed. Coders and providers are to continue using code 76937 as they previously were.

So, when is it appropriate to code 76937 add-on code in addition to your Interventional Radiology procedure? Documentation guidelines for reporting CPT code 76937 are as follows, per CPT Assistant Dec 2004 (pg. 6-13), when the CVAD codes were revised:

• “Pre-access assessment of venous patency and actual real-time visualization of needle passage to the venous lumen” (2024 NCCI Policy Manual).
• “Requires a permanent recorded image(s) of the vascular access site to be included in the patient record, as well as a documented description of the process either separately or within the procedure report” (2024 NCCI Policy Manual).

So, in cases where ultrasound is used solely to locate a vein, mark a skin entry point, and perform a puncture without guidance, it would not be suitable to use CPT code 76937 for ultrasound guidance.

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