Coding Q&A: Using a pressure-directed catheter for radioembolization of a hepatic tumor

Q: When an interventional radiologist uses a pressure-directed catheter for radioembolization of a hepatic tumor in the hospital outpatient setting, does this change the coding reported by the physician, i.e., does the physician report HCPCS (Healthcare Common Procedure Coding System) codes C1982 and C9797?

A: For a hepatic tumor(s) radioembolization, the codes reported by the physician are American Medical Association’s (AMA’s) Current Procedural Terminology (CPT) codes. CPT codes describe procedures and services provided by physicians, or other allied healthcare professionals, and are overseen by the AMA. Teams of radiologists and staff representing the Society of Interventional Radiology as well as American College of Radiology, American Roentgen Ray Society, Association of Academic Radiologists, and Radiology Society of North America attend three AMA CPT conferences a year where CPT codes are created.  CPT codes describe what the physician did during a procedure.

CMS has created its own reporting system for medical procedures and devices, known as the Healthcare Common Procedure Coding System, or HCPCS (pronounced “hick-picks”). CPT codes are owned by the AMA and cannot be directly used by CMS; however, Level 1 HCPCS codes use identical five-digit identifiers to those found in CPT. As such, the procedures described in CPT are still the basis for all procedures reported to CMS via HCPCS.

Level II HCPCS codes are alpha-numeric codes created to report ancillary services such as drugs, supplies (e.g., catheters), non-physician services and physician services not represented in within the CPT that may be reported along with other reportable services. Level II HCPCS codes begin with different letters to identify their subtype. Billing for items such as supplies and drugs with Level II HCPCS is done by the entity which purchased them for use in the procedure. In the facility setting (hospitals and ambulatory surgical centers), most supplies will begin with the letters C or A, while drugs begin with the letter J (unless still reported in a pass-through period). In the OBL, there may be opportunity to report supplies and drugs if they are not included within the practice expense for the procedure they are used with. It should be noted that OBLs and physicians cannot bill any HCPCS code that begins with the letter C as these HCPCS codes are solely for reporting by the facility setting. HCPCS codes that begin with the letter A and are not bundled into a procedure can be billed by the OBL.

The situation may rarely arise where a facility-based procedure is reported with a Level II HCPCS code (typically a C code) when a CMS-recognized procedure does not have a corresponding procedural code within the CPT. In this event, the physician would be expected to report the appropriate unlisted CPT code. Physicians do not report HCPCS codes for their work.

There are several IR procedures which are designated as device-intensive and will require the hospital or ASC to report a Level II HCPCS code for the device used, such as a catheter or stent. Failure to report the device code will result in denial of payment. CMS releases a list of device intensive procedures each year at the time of the final rule.

In the outpatient facility setting, the Level II HCPCS codes are reimbursed separately. While their costs are attributed to the Level I code reported, it is required to report the appropriate Level II codes for tracking and utilization purposes under the Hospital Outpatient Prospective Payment System (HOPPS) and ASC payment system. The hospital or ASC will bill for the procedure with the designated Level I HCPCS code (unless there is another coding convention applied based on other payment policies) and the Level II HCPCS code for the applicable supplies. The physician working in the facility setting (regardless of whether they are employed or a separate entity) will only report CPT codes for the procedure; they do not report any of the products, supplies, or drugs used during the procedure.

CMS oversees HCPCS Level II codes which are created following approval of an application at a separate meeting. Applications for code additions or changes are accepted each quarter for drugs and biologics, and if approved become effective 6 months following approval. Codes for non-drug and non-biological items are updated on a biannual cycle, with codes going into effect each July and April, depending on the application date.

In the case of the question posed, the physician will continue to code the tumor embolization CPT code 37243 regardless of what type of catheter is utilized for radioembolization of the hepatic tumor. They do not report any C code at any time, regardless of setting as the physician’s work is the same regardless of the site of service. From the technical side however, if the radioembolization is performed in the hospital outpatient setting or ASC, then the hospital or ASC will report the procedure with either CPT 37243 or C9797 (procedure code for vascular embolization or occlusion procedure with use of a pressure-generating catheter inclusive of all radiological supervision and interpretation (RS&I), intraprocedural road mapping and imaging guidance necessary to complete the intervention), depending on payor policy. Additionally, the facility would report C1982 (device code used for a catheter, pressure-generating, one-way valve, intermittently occlusive). Note there is a different procedure code for a mapping angiogram performed with a pressure directed catheter for use in the facility setting, C8004 (simulation angiogram with use of a pressure-generating catheter, inclusive of all RS&I, intraprocedural roadmapping, and imaging guidance necessary to complete the angiogram, for subsequent therapeutic radioembolization of tumors). In cases where a CPT code and a HCPCS Level II code exist for the same service or procedure, Medicare often requires the facility to report the HCPCS Level 2 code instead of the CPT code. As mentioned previously, an OBL cannot bill any C codes: they will report CPT codes for services performed in the office-based setting.

To simplify reimbursement, OPPS assigns services that are similar in cost, resources, and work into designated Ambulatory Payment Classification (APC) groups for payment. Every HCPCS/CPT code assigned to the same APC are paid the exact same amount. CMS does annual review of assignments to ensure the codes are all within an established threshold relative to each other and will move codes to new APCs when thresholds are exceeded, to ensure proper valuations.

A status indicator is used to establish a hierarchy within all available codes, and to identify those services which are conditionally or unconditionally packaged or paid separately under OPPS. For example, Level I HCPCS code 37243 is assigned a status indicator of J1, which represents the top of the hierarchy of codes/services; all ancillary services with status indicators (e.g. “S”, “T”, and “V”) reported on the same claim as a J code are considered to be packaged into payment of the J code, and will not be paid separately. When more than one J code is reported during the same procedure, typically only one will be reimbursed. However, some code combinations of primary services both assigned J1 may qualify for a complexity adjusted payment rate, which increases the reimbursement by shifting the procedure into the highest APC available within the family. It should be noted, any HCPCS code assigned a status indicator of “N” are never paid separately: these services are always packaged, but CMS requires they are still reported on the claim for tracking and utilization related to rate setting.

Disclaimer: SIR is providing this billing and coding guide for educational and information purposes only. It is not intended to provide legal, medical or any other kind of advice. The guide is meant to be an adjunct to the American Medical Association’s (AMA’s) Current Procedural Terminology (2026/CPT®). It is not comprehensive and does not replace CPT. Our intent is to assist physicians, business managers and coders. Therefore, a precise knowledge of the definitions of the CPT descriptors and the appropriate services associated with each code is mandatory for proper coding of physician service.

Every reasonable effort has been made to ensure the accuracy of this guide; but SIR and its employees, agents, officers and directors make no representation, warranty or guarantee that the information provided is error-free or that the use of this guide will prevent differences of opinion or disputes with payers. The publication is provided “as is” without warranty of any kind, either expressed or implied, including, but not limited to, implied warranties or merchantability and fitness for a particular purpose. The company will bear no responsibility or liability for the results or consequences of the use of this manual. The ultimate responsibility for correct use of the Medicare and AMA CPT billing coding system lies with the user. SIR assumes no liability, legal, financial or otherwise for physicians or other entities who utilize the information in this guide in a manner inconsistent with the coverage and payment policies of any payers, including but not limited to Medicare or any Medicare contractors, to which the physician or other entity has submitted claims for the reimbursement of services performed by the physician.