Unbundling CT Scans: A Renewed Focus


Generally, ‘bundled’ codes refer to procedure codes for less extensive exams being included in (or bundled with) procedure codes for more extensive exams being performed at the same anatomic location, or site.

For most CT scans, three separate CPT® code choices are available based on the site being studied: without contrast, with contrast and without and with contrast; where without and with contrast is considered the most extensive exam. For example:

74150  CT, abdomen; without contrast material

74160  CT, abdomen; with contrast material(s)

74170  CT, abdomen; without contrast material, followed by contrast material(s) and further sections

Unbundling refers to charging multiple CPT codes when a single, more extensive option exists. Per the NCCI Policy Manual for Medicare Services, Chapter IX, Section A: “A physician shall not report multiple HCPCS/CPT codes if a single HCPCS code exists that describes the services. This type of unbundling is incorrect coding.”

In the case of CT scans, the site-specific codes for without, with and without and with contrast should not be reported together when performed at the same encounter. This would fall into the territory of unbundling. As an example, for the above CT abdomen codes this would be reporting 74160 and 74170 together.


These rules are not new and shouldn’t be a surprise to anyone familiar with radiology CPT codes. So, why are we talking about this?

In February of 2019, the Centers for Medicare & Medicaid Services (CMS) Recovery Audit program announced that they would be auditing, and recovering overpayments for, unbundled CT scans. Per the release from CMS:

“This query identifies multiple units of CT scans billed on the same day by the same provider for the same beneficiary. The most extensive code should be the only code paid. The less extensive CT scan code(s) will be recovered as overpayments.”

See the list of codes being affected here →

With CT scans among the most common diagnostic imaging services performed, one mis-applied code has the potential to add up to a large financial impact. With recovery audit attention, it’s worth a second look to verify codes are being reported appropriately.


To ensure the proper code(s) are assigned for CT scans, each report needs to tell what was imaged and, more importantly, how it was imaged. There are five key elements that should be included in each report:

  1. What is the study? (i.e., CT, CTA)
  2. What anatomic area was studied?
  3. How was it imaged? Without contrast, with contrast or without and with contrast?
  4. What type of contrast was used?
  5. How much contrast was administered and, preferably, how much was discarded?

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