General Question for the Week of May 7, 2018

General Compliance Question of the Week


I read the answer to your March 19 question, and I don’t believe the response from MedLearn completely answers the question posed by the writer. Specifically:

  • The question did not mention anything about a patient being seen in different hospital departments.
  • The response refers to the NCCI Policy Manual for Medicare Services, chapter XI, section B, item 4, indicating that the following guideline can be found there: “When the PICC is inserted/placed by the same department (cost center) then the IV Infusion/injection is considered a component of the procedure and not separately billable.” However, I do not see any reference in the NCCI manual guidance about the same department (cost center). For this chapter, go to file:///C:/Users/Tillie/AppData/Local/Temp/

My interpretation of the NCCI manual guidance, item 4 is as follows: It states that placement of peripheral vascular access devices is integral to IV infusion and injections and not separately reportable (e.g., 36000—introduction of needle/catheter into vein), 36410—venipuncture). This guidance is also documented in the CPT manual under the Vascular Injection Procedures section, which is referring to intravenous injection procedures into veins and arteries or catheters (e.g., peripheral IV access.)

However, per the NCCI guidance, if it is central venous access (e.g., CPT 36568, 36569), which is not routinely necessary to perform infusions/injections, this service MAY be reported separately. Central venous access procedures are different than vascular injection procedures.

So, if a PICC meets the description of a peripherally inserted central venous catheter (per the CPT manual) “to qualify as a central venous access catheter or device, the tip of the catheter/device must terminate in the subclavian, brachiocephalic (innominate) or iliac veins, the superior or inferior vena cava , or the right atrium” then when CPT codes for central venous access catheter procedures are reported with a CPT code for the IV infusion/injection administered on the same day, per the CPT manual and NCCI manual guidance and instruction it is appropriate to report it with the -59 or XU modifier regardless of the same department or revenue center.

I would appreciate your review of the initial question and my comments and any additional explanation or information you could provide on this issue.


We agree with your assessment of the language found in the 2018 NCCI Policy Manual for Medicare Services, Chapter XI. Based on the CPT codebook, PICC lines are considered a central venous device. In response to your original question, PICC line insertion (36568 or 36569) may be reported on the same day as the applicable drug-administration code(s) (96365, 96366, 96367, 96368). The code for the PICC line insertion will require modifier 59 or XU (unusual non-overlapping service) to bypass NCCI edits. Modifier XU is most specific, but the choice of modifier will depend on payer billing requirements.

Disclaimer: Every reasonable effort was made to ensure the accuracy of this information at the time it was published. However, due to the nature of industry changes over time we cannot guarantee its validity after the year it was published.