September 5, 2023
The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1786-P
P.O. Box 8010
Baltimore, MD 21244-1810
Submitted online via www.regulations.gov

Re: File Code CMS-1786-P Hospital Outpatient Prospective Payment and Ambulatory SurgicalCenter Payment Systems and Quality Reporting Programs; Proposed Rule
Dear Administrator Brooks-LaSure:

The American Association of Oral and Maxillofacial Surgeons (AAOMS) represents more than 9,000
oral and maxillofacial surgeons (OMSs) in the United States. AAOMS appreciates the opportunity tocomment on the proposed 2024 revisions to the Hospital Outpatient Prospective Payment (OPPS)
and Ambulatory Surgical Center (ASC) Payment Systems Proposed Rule, published in the July 31,
2023, Federal Register (Vol. 88, No. 145, pages 49552-49921).

AAOMS commends CMS on efforts to improve access to high-quality and affordable health care,specifically, the proposals aimed at ensuring Medicare beneficiaries have access to medicallynecessary and essential dental services in hospitals and ambulatory surgery centers.

Through this letter, we provide recommendations and seek clarification on select aspects of the
proposals impacting payment for dental services under both the OPPS and ASC payment system.
Prefatory Comment

We understand that, while CMS had opted for a catch-all approach with the introduction of theG0330 code in the hospital outpatient setting in 2023, CMS has taken a different approach for 2024
by proposing the addition of numerous individual dental procedures with their own facility rates
for both hospital and ASC settings, relegating 2024 use of the G0330 code to when other covered
and payable codes are inapplicable. Our comments provided herein are not intended to recommend
one approach over the other as AAOMS recognizes that each has its merits and challenges. Rather,
our comments are intended to work with the direction that CMS has proposed for 2024 byPage 1

providing guidance for more accurate assignment of codes and to seek clarity for provisions of the
proposal that may be unclear.
Hospital outpatient payment for dental services

Assignment of CDT©1 codes to clinical Ambulatory Payment Classifications
As indicated in prior comments, we support Medicare coverage and payment for dental services
furnished to identify, diagnose and treat oral or dental infections linked to certain acute conditions
and Medicare-covered therapies. This includes the clinical scenarios outlined in the CY 2023
Medicare Physician Fee Schedule (MPFS) final rule1 and those proposed by CMS in the CY 2024
MPFS proposed rule2. OMSs routinely evaluate and safely treat patients ranging in complexity
across a variety of care settings, therefore AAOMS continues to support Medicare coverage of suchdental services in both inpatient and outpatient hospital settings.

Assigning additional dental procedure codes to clinical APCs would allow hospital outpatient
departments to receive facility payment for dental services that meet the threshold for Medicare
coverage, if finalized. This is consistent with the coverage and payment policies for inextricably
linked dental services CMS has established under the MPFS to date. As such, AAOMS appreciates
CMS’s proposal to assign 229 CDT© codes to clinical APCs, permitting Medicare payment to be madefor medically necessary dental services furnished in the hospital outpatient setting when all
Medicare coverage and payment criteria are met.

Request for additional dental surgical procedures to be payable in the hospital outpatient setting

In addition to the dental procedures outlined in the CY 2024 OPPS/ASC proposed rule, AAOMS
continues to believe there are additional dental surgical procedures that may be medicallynecessary to treat oral or dental infections for patients with certain acute conditions and therefore
may meet the threshold for Medicare coverage and payment. Further, these procedures areappropriate for payment under the OPPS, as they may be furnished safely in the hospital outpatientsetting.
Consistent with our prior recommendations, AAOMS encourages CMS to consider thefollowing dental surgical procedures for coverage in the hospital outpatient setting:
•
•
•
•
•
•
•
•
•

Coronectomy as described by CDT© code D7251.
Surgical procedures to facilitate tooth eruption as described by CDT© codes D7280 and D7283.
Alveoloplasty or ridge preparation procedures as described by CDT© codes D7320 and D7321.
Excision of benign soft tissue lesions as described by CDT© codes D7410, D7411 and D7412.
Excision of malignant soft tissue lesions as described by CDT© codes D7413, D7414 and D7415.
Excision of malignant intra-osseous lesions as described by CDT© codes D7440 and D7441.
Excision of benign intra-osseous lesions as described by CDT© codes D7450 and D7451.
Removal of lateral exostosis of the jaws as described by CDT© code D7471.
Surgical removal of foreign body from mucosa, skin, subcutaneous alveolar tissue or themusculoskeletal system as described by CDT© codes D7530 and D7540.

1 CDT© is a registered trademark of the American Dental Association.

Page 2

If the above procedures are included for coverage in the hospital outpatient setting, AAOMS
requests that they be assigned to clinical APCs as provided in Appendix A.
Request for clarification on the proposed payment rate for APC 5871 Dental Procedures
In the CY 2024 OPPS/ASC proposed rule, CMS notes that it is common for a patient to undergo
multiple dental procedures during the same surgical encounter, as well as for dental services to be
performed contemporaneously with other medical services. AAOMS agrees. If CMS’s proposal toassign over 200 additional CDT© codes to clinical APCs is finalized, it is our understanding that ahospital would be able to bill and receive payment for each Medicare-covered procedure —including covered dental services — assigned a facility payment rate.

However, AAOMS seeks clarification on the proposed CY 2024 payment rate of $938.69
assigned to APC 5871 Dental Procedures as this represents a decrease of over 45 percent
from 2023. APC 5871 comprises a significant number of dental services, and data presented in the
CY 2024 proposed rule indicate that the hospital outpatient claims used in the calculation of thepayment rate for APC 5871 include a wide range of geometric mean costs, from approximately $17
to nearly $7,900.

We note that statute requires APCs to be comprised of services comparable in both clinicalcharacteristics and cost. Therefore, based on the broad range of geometric mean costs in the data,
we question as to whether the CY 2024 proposed payment rate for APC 5871 is truly representativeof clinically similar, cost comparative services. Clarification on how the proposed payment rate wasderived would help us and other interested parties engage with CMS on policy-related issues
regarding the payment for Medicare-covered dental services under the OPPS.
Request for APC reassignment for select services under the OPPS

Currently, there are several codes payable under the OPPS an OMS may use to report certain typesof services for which a hospital outpatient setting is deemed clinically appropriate. This includes
both CPT©2 and CDT© codes, with many of the dental codes assigned to APC 5871. Also, a significant
number of the dental codes proposed for coverage under the OPPS for 2024 will be assigned to APC
5871, if finalized.
In particular, we note the dental procedure codes – both currently payable and proposed under the
OPPS for 2024 – have comparable medical procedure codes. In many cases, the respective CPT©
crosswalks for these dental codes are assigned to other clinical APCs carrying payment rates higher
than what is proposed for APC 5871 for CY 2024. If finalized, this means a medical code and adental code describing the same service could be paid at different rates at the facility level, eventhough resource costs are equivalent.
An assignment to clinical APC 5871 for dental oral and maxillofacial surgery codes does notaccurately capture the clinical complexity and costs associated with these procedures, and CDT©
and CPT© codes describing clinically equivalent procedures should not have different facility
payment rates under the OPPS. Further, while we understand CMS’s methodology generally uses
both clinical characteristics and resource costs to assign a service or code to what is deemed an
2 CPT © is a registered trademark of the American Medical Association.

Page 3

appropriate clinical APC, we note the specific criteria governing how individual levels are
determined is unclear.

Based on the above, additional time and information from CMS is needed to suggest accurate
APC assignments for dental procedures currently payable under the OPPS and those
proposed for assignment to clinical APCs for 2024. In the interim, AAOMS has developed
recommendations for APC reassignment for select dental codes, as provided in Appendix B.
However, AAOMS recommends continued review for accurate APC assignment.
Request for clarification on the use of clinical experts and crosswalking
In CMS’s proposal to assign select dental procedure codes to clinical APCs, the Agency indicates it
consulted with clinical experts to discuss the clinical aspects of each dental service, as well as learn
about the resources and supplies used to perform them. CMS states this was done to accurately
identify crosswalk codes and propose APC assignments for dental services, specifically in theabsence of cost data.

We acknowledge the Advisory Panel on Hospital Outpatient Payment (HOP Panel) plays an integralrole in the configuration of APCs under the OPPS. Indeed, the Panel is charged with assessing theclinical integrity of APCs and their associated weights. From our review of the proposed rule, we
understand this may include evaluating the clinical and procedural details of an item or service,analyzing resource cost and frequency data, as well as crosswalk code analysis.

With the proposed assignment of over 200 dental procedure codes to clinical APCs, we believe it
imperative for the HOP Panel to include a dental practitioner. A dentist or dental surgical specialist
may advise on the clinical details and resource costs of dental procedures, which may help to
inform appropriate APC assignment and facility payment for these services. As such, AAOMS
requests the inclusion of a dentist or dental specialist on the Advisory Panel on Hospital
Outpatient Payment.
ASC payment for dental services
Addition of CDT© codes to the ASC Covered Procedures List

AAOMS appreciates CMS’s proposal to add 26 dental surgical services to the ASC Covered
Procedures List (CPL), including HCPCS code G0330. Access to medically necessary dental services
may be critical to successful outcomes for patients with certain acute conditions. As OMSs routinely
evaluate and safely treat patients ranging in complexity across a variety of care settings, we support
Medicare coverage for such dental services in both inpatient and outpatient hospital settings, aswell as the ASC.
However, we encourage CMS to consider extending coverage for medically necessary dental
services to identify, diagnose and treat oral or dental infections, as outlined under the MPFS whenrendered in ambulatory surgery centers.

Services to eliminate an oral or dental infection may include, but are not limited to, the extraction ofteeth, intraoral and extraoral incision and drainage procedures and partial
ostectomy/sequestrectomy for removal of non-vital bone, all of which are surgical procedures CMS
proposes to allow payment when furnished in the ASC, providing all Medicare coverage andpayment criteria are met. Currently, coverage and payment under the MPFS for dental services

Page 4performed to identify, diagnose and treat oral or dental infections prior to or contemporaneouslywith Medicare covered organ transplant surgery, cardiac valve replacement and valvuloplasty
procedures, as well as covered treatments for head and neck cancer beginning in 2024 and the
proposals outlined in the 2024 MPFS proposed rule, is limited to hospital inpatient and outpatientsettings.

Permitting Medicare payment in the ASC for inextricably linked and medically necessary dental
surgical services furnished to identify, diagnose and treatment oral or dental infections prior to, orat the same time as, select covered medical procedures would help to ensure the consistent
application of Medicare dental coverage and payment policies across care settings.

Further, we believe that ASCs have the potential to mitigate many of the external pressures thatcurrently act as barriers in access to care. The lack of and/or limited hospital-based OR access is
exacerbated by ongoing medical staffing shortages and industry-wide inflation. Other challenges
exist for patients unable to access hospital facilities because of geographic or transportation
limitations. Indeed, industry research indicates the health care system as a whole benefits whenprocedures migrate to less costly care settings. As such, AAOMS encourages CMS to aligncoverage policies under the MPFS and the ASC payment system to allow Medicare coverageand payment for dental surgical services to identify, diagnose and treat oral or dental
infections, when inextricably linked to the clinical scenarios finalized in the 2023 MPFS final
rule and those proposed in the 2024 MPFS proposed rule.
AAOMS further recommends the following CDT© codes for addition to the ASC CPL:
•
•
•
•
•
•
•
•
•
•
•

Coronectomy as described by CDT© code D7251.
Surgical procedures to facilitate tooth eruption as described by CDT© codes D7280 and D7283.
Alveoloplasty or ridge preparation procedures as described by CDT© codes D7320 and D7321.
Excision of benign soft tissue lesions as described by CDT© codes D7410, D7411 and D7412.
Excision of malignant soft tissue lesions as described by CDT© codes D7413, D7414 and D7415.
Excision of malignant intra-osseous lesions as described by CDT© codes D7440 and D7441.
Excision of benign intra-osseous lesions as described by CDT© codes D7450 and D7451.
Removal of benign nonodontogenic cysts and tumors as described by CDT© codes D7460 andD7461.
Excision of bone tissue, including exostosis and reduction of osseous tuberosity as describedby CDT© codes D7471 and D7485, respectively.
Surgical incision and drainage of extraoral soft tissue (complicated) as described by CDT© code
D7521.
Surgical removal of foreign body from mucosa, skin, subcutaneous alveolar tissue or themusculoskeletal system as described by CDT© codes D7530 and D7540.

We believe it can be demonstrated3 these procedures:
•
•
•
•
•

Page 5

Do not generally result in extensive blood loss.
Do not require major or prolonged invasion of body cavities.
Do not directly involve major blood vessels.
Are generally not emergent or life threatening.
Do not commonly require systemic thrombolytic therapy.

•••Are not designated as requiring inpatient care.
Are not limited to a CPT unlisted surgical procedure code.
Are not other excluded by current regulation.

Consideration of other surgical procedures for addition to the ASC CPL
As indicated in prior comments, AAOMS supports CMS’s overarching commitment to patient safety.
However, we reiterate that evolving technology and treatment modalities have allowed forincreasingly complex procedures to be performed safely and efficiently across a wide range of caresettings, including ambulatory surgery centers. As such, we again encourage CMS to consider thefollowing procedures for addition to the ambulatory surgery center coverage list:••••

21193 Reconstruction of mandibular rami, horizontal, vertical, C, or L osteotomy;
without bone graft21194 Reconstruction of mandibular rami, horizontal, vertical, C, or L osteotomy;
with bone graft (includes obtaining graft)
21195 Reconstruction of mandibular rami and/or body, sagittal split; without
internal rigid fixation
21196 Reconstruction of mandibular rami and/or body, sagittal split; with internal
rigid fixation

The AAOMS Committee on Healthcare Policy, Coding and Reimbursement convened a special panelof surgeons with extensive experience performing orthognathic surgery to evaluate whether
certain oral and maxillofacial surgical procedures meet the criteria for addition to the ASC CPL.
Through a retrospective case log review and comprehensive search of current scientific literatureand perioperative protocols for orthognathic surgery procedures, the panel identified and reachedan expert consensus on the recommendation of four codes to the ASC CPL for CY 2024, as indicatedabove.

Based on the analysis of the expert panel, it was determined these procedures did not violate any ofthe established patient safety criteria3 to warrant exclusion from the ASC setting. We note themitigation of hemorrhage risk associated with certain orthognathic surgical procedures is offundamental concern to the OMS when treatment planning and furnishing orthognathic surgicalprocedures. Outlined below, we reiterate the panel’s findings as they pertain to blood loss for therecommended surgical procedures of the mandible.

The panel concluded that blood loss for these reconstructive procedures was typically minimal,
with an average blood loss of 100cc or 100mL. This is consistent with Chen et al. 4 that reported anaverage interoperative blood loss of 105.9mL in patients undergoing bilateral vertical ramus
osteotomy. A literature review by Lee et al.5 that found the mean intraoperative blood loss for atypical single-jaw orthognathic case, specifically either a sagittal split ramus osteotomy (SSRO) or
intraoral vertical ramus osteotomy (IVRO) ranges from 55 to 167mL and 82 to 104mL, respectively.

Further, implementation of advanced clinical protocols in conjunction with orthognathic surgery
has been shown to improve patient outcomes by shortening length of stay, facilitating
postoperative pain control and decreasing the incidence of postsurgical complications including
nausea and vomiting6. Specifically, the Enhanced Recovery After Surgery (ERAS) protocol has been
adopted across multiple specialties and represents a systematic, multimodal approach to improving
patient outcomes7. A retrospective cohort study of 359 patients found the implementation of ERAS
Page 6

protocols led to a decrease in estimated blood loss and in overall length of stay, allowing for safeand effective same-day discharge for patients undergoing extensive bimaxillary or two-jaw
orthognathic surgery7.

Other factors have contributed to the mitigation of hemorrhage risk associated with certain
orthognathic surgical procedures, particularly those described by codes 21193, 21194, 21195 and21196. For instance, technique advancement by way of efficiencies from virtual surgical planning
has allowed surgeons to better anticipate issues intraoperatively, such as predicting bony
interferences or the position of the inferior alveolar nerve.
Request to move surgical CDT© codes from the ASC ancillary services list to the CPL

Balancing financial considerations with the goal of providing quality care to patients is an ongoingchallenge in the healthcare industry. Although we recognize the necessity of setting coverage andpayment restrictions for certain services considered supplemental, integral to or furnished insupport of other covered surgical procedures, we believe several of the CDT© codes proposed for
addition to the ASC covered ancillary services list may be themselves considered to be primary
surgical services as opposed to supportive or ancillary.

The proposed addition of dental surgical procedures to the list of ASC covered ancillary services
appears inconsistent with the current structure of the ASC ancillary services list. For example, the2023 list generally consists of radiology services, examinations and drugs, biologicals and othersupplies for which separate payment is not permitted under the ASC payment system as opposed tosurgical procedures. For 2024, CMS is not proposing to classify any other surgical procedures ascovered ancillary services in the ASC, except for select dental procedures. As indicated by CMS,
these services are safely furnished in the ASC and we believe they warrant separate payment.
Therefore, AAOMS asks CMS to reassign all dental surgical procedures described by theirrespective CDT© codes from the ASC ancillary services list to the ASC Covered Procedures
List, as provided in Appendix C. Dental codes that describe radiologic services, diagnostic
imaging, supplies and examinations for packaged payment under the ASC payment system may
remain as covered ancillary dental services.

Thank you for your consideration of these comments. Please contact Patricia Serpico, AAOMS
Director of Health Policy, Quality and Reimbursement, with any questions at 800-822-6637, ext.
4394 or pserpico@aaoms.org.
Sincerely,

Paul J. Schwartz, DMD
AAOMS President
Joshua E. Everts, DDS, MD, FACS
Chair, AAOMS Committee on Healthcare Policy, Coding & Reimbursement
Page 7References
1 Centers for Medicare & Medicaid Services, Health and Human Services. (2022, November 18).
Medicare and Medicaid Programs; CY 2023 Payment Policies Under the Physician Fee Schedule andOther Changes to Part B Payment and Coverage Policies Final Rule.
https://www.federalregister.gov/documents/2022/11/18/2022-23873/medicare-and-medicaidprograms-cy-2023-payment-policies-under-the-physician-fee-schedule-and-other

2 Centers for Medicare & Medicaid Services, Health and Human Services. (2023, August 7).
Medicare and Medicaid Programs; CY 2024 Payment Policies Under the Physician Fee Schedule andOther Changes to Part B Payment and Coverage Policies Proposed Rule.
https://www.federalregister.gov/documents/2023/08/07/2023-14624/medicare-and-medicaidprograms-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other3 Covered Surgical Procedures, 42 CFR § 416.166

4 Chen, H.S., Lai, S.S.T., Lee, K.T., Lee, H.E. and Hsu, K.J. (2013). Intraoperative blood loss during anosteotomy of the bilateral vertical ramus. Journal of Dental Sciences, 9(3). 249-252.
https://doi.org/10.1016/j.jds.2013.04.008

5 Lee, K.T., Lin, S.S., Hsu, K.J., Tsai, C.Y., Lee, Y.H., Change, Y.J. and Wu, T.J. (2021). Intraoperative
blood loss and postoperative pain in the sagittal split ramus osteotomy and intraoral vertical ramus
osteotomy: A literature review. BioMed Research International, 2021.
https://doi.org/10.1155/2021/4439867

6 Stratton, M., Waite, P.D., Powell, K.K., Scopel, M.M. and Kukreja, P. (2021). Benefits of the enhanced
recovery after surgery pathway for orthognathic surgery. International Journal of Oral &Maxillofacial Surgery,51(2). 214-218. https://doi.org/10.1016/j.ijom.2021.04.008
7 Ferrara, J.T., Tehrany, G.M., Chen, Q., Sheinbaum, J., More-Marquez, J., Hernandez Conte, A., andRudikoff, A.G. (2021). Evaluation of an enhanced recovery after surgery protocol (ERAS) for sameday discharge and reduction of opioid use following bimaxillary surgery. Journal of Oral &Maxillofacial Surgery, 80(1). 38-46. https: doi.org/10.1016/j.joms.2021.07.002

Page 8

Appendix A

AAOMS recommendations for dental surgical procedures for coverage under the OPPS and ASC payment system andcorresponding clinical APCs for CY 2024

HCPCS Code
D7251

Nomenclaturecoronectomy - intentional partial tooth
removal, impacted teeth only

Possible CPT
Crosswalk

CMS Assigned
APC for Crosswalk AAOMS Recommendation for CY 2024
Assign to clinical APC 5871 Dental
Procedures
Assign to clinical APC 5871 Dental
Procedures
Assign to clinical APC 5871 Dental
Procedures

D7321

exposure of an unerupted tooth
placement of device to facilitate eruption of
impacted tooth
alveoloplasty not in conjunction withextractions - four or more teeth or tooth
spaces, per quadrant
alveoloplasty not in conjunction withextractions - one to three teeth or tooth
spaces, per quadrant

D7410

excision of benign lesion up to 1.25 cm

Assign to clinical APC 5164 Level 4 ENT
Procedures
Recommend APC 5163 Level 3 ENT,
Otherwise, APC 5072 Level 2 Excision/
Biopsy/ Incision andexcision of benign lesion greater than 1.25 cm

For D7410-D7412: Recommend APC 5163
Level 3 ENT, Otherwise, APC 5072 Level 2
Excision/ Biopsy/ Incision and

D7280
D7283

D7320

D7411

D7412

D7413

excision of benign lesion, complicatedexcision of malignant lesion up to 1.25 cm

41874 APC 5164

41874 APC 5164

Assign to clinical APC 5164 Level 4 ENT
Procedures

Recommend APC 5163 Level 3 ENT,
Otherwise, APC 5072 Level 2 Excision/
Biopsy/ Incision and Drainage
Recommend APC 5164 Level 4 ENT like
CPT 40810, Otherwise, APC 5073 Level 3
Excision/ Biopsy/ Incision and Drainage

excision of malignant lesion greater than 1.25
cm

Recommend APC 5164 Level 4 ENT like
CPT 40810, Otherwise, APC 5073 Level 3
Excision/ Biopsy/ Incision and Drainage

excision of malignant lesion, complicatedRecommend APC 5164 Level 4 ENT like
CPT 40810, Otherwise, APC 5073 Level 3
Excision/ Biopsy/ Incision and Drainage

excision of malignant tumor - lesion diameter
up to 1.25 cm

Recommend APC 5164 Level 4 ENT like
CPT 40810, Otherwise, APC 5073 Level 3
Excision/ Biopsy/ Incision and Drainage

D7441

excision of malignant tumor - lesion diameter
greater than 1.25 cm

Recommend APC 5164 Level 4 ENT like
CPT 40810, Otherwise, APC 5073 Level 3
Excision/ Biopsy/ Incision and Drainage

D7450

removal of benign odontogenic cyst or tumor lesion diameter up to 1.25 cm

Recommend APC 5164 Level 4 ENT like
CPT 40810, Otherwise, APC 5073 Level 3
Excision/ Biopsy/ Incision and Drainage

D7414

D7415

D7440

removal of benign odontogenic cyst or tumor lesion diameter greater than 1.25 cm
removal of lateral exostosis (maxilla or
mandible)
D7471
removal of foreign body from mucosa, skin,or subcutaneous alveolar tissue
D7530
removal of reaction producing foreign bodies,musculoskeletal system
D7540©
CDT is a registered trademark of the American Dental Association.
D7451

41823 APC 5165
41805 APC 5163
41805 APC 5163

Recommend APC 5164 Level 4 ENT like
CPT 40810, Otherwise, APC 5073 Level 3
Excision/ Biopsy/ Incision and Drainage
Assign to clinical APC 5165 Level 5 ENT
Procedures
Assign to clinical APC 5163 Level 3 ENT
Procedures
Assign to clinical APC 5163 Level 3 ENT
Procedures

Appendix B
AAOMS recommendations regarding select dental surgical services for CY 2024

HCPCS CodeNomenclature

CMS Proposed Clinical
APC for CY 2024

CDT Codes with Current APCs/Currently Payable in Outpatient Setting

APC 5521 Level 1 Imaging
without Contrast

D0240

intraoral - occlusal radiographic image

D0250

extra-oral - 2D projection radiographic
image created using a stationary radiation APC 5521 Level 1 Imaging
without Contrast
source, and detector

D0251

extra-oral posterior dental radiographic
image

APC 5521 Level 1 Imaging
without Contrast

D0272

bitewings - two radiographic images

APC 5521 Level 1 Imaging
without Contrast

D4264

bone replacement graft - retained natural
tooth - each additional site in quadrant

D4268

surgical revision procedure, per tooth

D7220

removal of impacted tooth - soft tissue

NA (Packaged)
APC 5871 Dental
Procedures

Possible CPT
Crosswalk

CMS Assigned APC for
Crosswalk (for CY 2023 AAOMS Recommendation forand proposed for 2024) CY 2024
Reassign to APC 5523 Level 3
APC 5523 Level 3 Imaging Imaging without Contrast to alignwith 70310
70310 without Contrast
Reassign to APC 5523 Level 3
APC 5523 Level 3 Imaging Imaging without Contrast to alignwith 70310
70310 without Contrast
Reassign to APC 5523 Level 3
APC 5523 Level 3 Imaging Imaging without Contrast to alignwith 70310
70310 without Contrast
Reassign to APC 5523 Level 3
APC 5523 Level 3 Imaging Imaging without Contrast to alignwith 70310
70310 without Contrast
Add to ASC CPL under the ASC
payment system
Add to ASC CPL under the ASC
payment system

D7240

APC 5871 Dental
Procedures
APC 5871 Dental
removal of impacted tooth - partially bony Procedures
removal of impacted tooth - completely
APC 5871 Dental
bony
Procedures

Reassign to APC 5163 Level 3 ENT
Procedures
Reassign to APC 5163 Level 3 ENT
Procedures
Reassign to APC 5164 Level 4 ENT
Procedures

D7241

removal of impacted tooth - completely
bony, with unusual surgical complications

Reassign to APC 5164 Level 4 ENT
Procedures

D7230

APC 5871 Dental
Procedures

D7260oroantral fistula closure

APC 5871 Dental
Procedures

D7261

primary closure of a sinus perforation

APC 5871 Dental
Procedures

APC 5054 Level 4 Skin
14040 Procedures

Reassign to APC 5165 Level 5
ENT Procedures to align with
30580
Reassign to either:1.) APC 5054 Level 4 Skin
Procedures to align with 14040
2.) APC 5165 Level 5 ENT
Procedures to be consistent withclinically similar dental service
D7260

D7940

APC 5871 Dental
osteoplasty - for orthognathic deformities Procedures

APC 5165 Level 5 ENT
21208 Procedures

Reassign to APC 5165 Level 5 ENT
Procedures to align with 21208

Facility services for dental rehabilitation
procedure(s) performed on a patient who
requires monitored anesthesia (e.g.,general, intravenous sedation (monitored
anesthesia care) and use of an operating APC 5871 Dental
Procedures
room
G0330
CDT Codes Proposed for Assignment to Clinical APCs for CY 2024

D0321

other temporomandibular joint
radiographic images, by report

APC 5521 Level 1 Imaging
without Contrast

D0364

cone beam CT capture and interpretation
with limited field of view - less than one
whole jaw

APC 5522 Level 2 Imaging
without Contrast

D0365

cone beam CT capture and interpretation
with field of view of one full dental arch mandible

APC 5522 Level 2 Imaging
without Contrast

APC 5165 Level 5 ENT
30580 Procedures

Reassign to APC 5164 Level 4 ENT
Procedures
Reassign to APC 5523 Level 3
Imaging without Contrast to alignAPC 5523 Level 3 Imaging with 70332 and clinically similar
dental service D0320
70332 without Contrast
the CPT crosswalk 70486 is
assigned to the same APC as
proposed. However, D0330 has
APC 5523 Level 3 Imaging w/ocontrast, should CBCT be
70486
consistent with a pano.
the CPT crosswalk 70486 is
assigned to the same APC as
proposed. However, D0330 has
APC 5523 Level 3 Imaging w/ocontrast, should CBCT be
70486
consistent with a pano.

D0366cone beam CT capture and interpretation
with field of view of one full dental arch maxilla, with or without cranium

APC 5522 Level 2 Imaging
without Contrast

70486

D0367

cone beam CT capture and interpretation
with field of view of both jaws; with orwithout cranium

APC 5522 Level 2 Imaging
without Contrast

70486

D0368

cone beam CT capture and interpretation
for TMJ series including two or more
exposures

APC 5522 Level 2 Imaging
without Contrast

70486

D0369

maxillofacial MRI capture andinterpretation

APC 5522 Level 2 Imaging
without Contrast

D0370

maxillofacial ultrasound capture andinterpretation

APC 5522 Level 2 Imaging
without Contrast

D0371

APC 5521 Level 1 Imaging
sialoendoscopy capture and interpretation without Contrast

the CPT crosswalk 70486 is
assigned to the same APC as
proposed. However, D0330 has
APC 5523 Level 3 Imaging w/ocontrast, should CBCT beconsistent with a pano.
the CPT crosswalk 70486 is
assigned to the same APC as
proposed. However, D0330 has
APC 5523 Level 3 Imaging w/ocontrast, should CBCT beconsistent with a pano.
the CPT crosswalk 70486 is
assigned to the same APC as
proposed. However, D0330 has
APC 5523 Level 3 Imaging w/ocontrast, should CBCT beconsistent with a pano.

Depending on whether contrast
is used, reassign to either:
APC 5523 Level 3 Imaging 1.) APC 5523 Level 3 Imaging with
Contrast
without Contrast/APC
5572 Level 2 Imaging with 2.) APC 5572 Level 2 Imaging with
70540/70542 Contrast
Contrast
Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging with
Contrast
2.) APC 5572 Level 2 Imaging with
76536
Contrast
APC 5523 Level 3 Imaging
APC 5523 Level 3 Imaging without Contrast to align with
70390 without Contrast
70390

D0380

D0381

D0382

D0383

D0384

APC 5522 Level 2 Imaging
without Contrast

Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging
without Contrast
2.) APC 5572 Level 2 Imaging with
Contrast

APC 5522 Level 2 Imaging
without Contrast

Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging
without Contrast
2.) APC 5572 Level 2 Imaging with
Contrast

cone beam CT image capture with field ofview of one full dental arch - maxilla, with APC 5522 Level 2 Imaging
or without cranium
without Contrast

Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging
without Contrast
2.) APC 5572 Level 2 Imaging with
Contrast

cone beam CT image capture with field of APC 5522 Level 2 Imaging
view of both jaws; with or without cranium without Contrast

Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging
without Contrast
2.) APC 5572 Level 2 Imaging with
Contrast

cone beam CT image capture for TMJ
series including two or more exposures

Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging
without Contrast
2.) APC 5572 Level 2 Imaging with
Contrast

cone beam CT image capture with limited
field of view - less than one whole jaw

cone beam CT image capture with field ofview of one full dental arch - mandible

APC 5522 Level 2 Imaging
without Contrast

D0385

D0386

D4261

D7310

D7311

maxillofacial MRI image capture

maxillofacial ultrasound image capture
osseous surgery (including elevation of afull thickness flap and closure) - one tothree contiguous teeth or tooth bounded
spaces per quadrant
alveoloplasty in conjunction withextractions - four or more teeth or tooth
spaces, per quadrant
alveoloplasty in conjunction withextractions - one to three teeth or tooth
spaces, per quadrant

APC 5522 Level 2 Imaging
without Contrast

Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging
without Contrast
2.) APC 5572 Level 2 Imaging with
Contrast

APC 5522 Level 2 Imaging
without Contrast

Depending on whether contrast
is used, reassign to either:1.) APC 5523 Level 3 Imaging
without Contrast
2.) APC 5572 Level 2 Imaging with
Contrast

APC 5164 Level 4 ENT
Procedures

APC 5165 Level 5 ENT
41823 Procedures

Reassign to APC 5165 Level 5 ENT
Procedures to align with 41823

APC 5163 Level 3 ENT
Procedures

APC 5164 Level 4 ENT
41874 Procedures

Reassign to APC 5164 Level 4 ENT
Procedures to align with 41874

APC 5163 Level 3 ENT
Procedures

APC 5164 Level 4 ENT
41874 Procedures

Reassign to APC 5164 Level 4 ENT
Procedures to align with 41874
Reassign to APC 5164 Level 4 ENT
Procedures to align with 41874

D7460

removal of benign nonodontogenic cyst or APC 5871 Dental
tumor - lesion diameter up to 1.25 cm
Procedures

APC 5164 Level 4 ENT
41825/41826 Procedures

Add to ASC CPL under the ASC
payment system
Reassign to APC 5164 Level 4 ENT
Procedures to align with 41874

D7461

removal of benign nonodontogenic cyst or
tumor - lesion diameter greater than 1.25 APC 5871 Dentalcm
Procedures

APC 5164 Level 4 ENT
41825/41826 Procedures

D7472

removal of torus palatinus

APC 5871 Dental
Procedures

APC 5164 Level 4 ENT
21032 Procedures

Add to ASC CPL under the ASC
payment system
Reassign to APC 5164 Level 4 ENT
Procedures to align with 21032

D7473

D7485

D7510

D7511

removal of torus mandibularis

APC 5871 Dental
Procedures

APC 5164 Level 4 ENT
21031 Procedures

Reassign to APC 5164 Level 4 ENT
Procedures to align with 21031
AAOMS agrees with CMS's
proposed APC assignment under
the OPPS

reduction of osseous tuberosity

APC 5165 Level 5 ENT
Procedures

APC 5165 Level 5 ENT
41823 Procedures

Add to ASC CPL under the ASC
payment system
Recommend APC 5163 like CPT
crosswalk 41018. Otherwise,level 1 or 2 Excision, Biopsy, may
be more appropriate.

APC 5071 Level 1
incision and drainage of abscess - intraoral Excision/Biopsy/Incisionsoft tissue
and Drainage

Recommend APC 5163 like CPT
crosswalk 41018. Otherwise,level 1 or 2 Excision, Biopsy, may
be more appropriate.

incision and drainage of abscess - intraoral APC 5071 Level 1
soft tissue - complicated (includes drainage Excision/Biopsy/Incision
and Drainageof multiple fascial spaces)

D7520

APC 5071 Level 1
incision and drainage of abscess - extraoral Excision/Biopsy/Incision
and Drainage
soft tissue

D7521

incision and drainage of abscess - extraoral APC 5071 Level 1
soft tissue - complicated (includes drainage Excision/Biopsy/Incision
and Drainageof multiple fascial spaces)

partial ostectomy/sequestrectomy for
APC 5871 Dental
removal of non-vital bone
Procedures
D7550©
CDT is a registered trademark of the American Dental Association.
CPT © is a registered trademark of the American Medical Association.

Recommend APC 5163 like CPT
crosswalk 41018. Otherwise,level 1 or 2 Excision, Biopsy, may
be more appropriate.

Add to ASC CPL under the ASC
payment system
APC 5164 Level 4 ENT
41830 Procedures

Reassign to APC 5164 Level 4 ENT
Procedures to align with 41830

Appendix C
AAOMS recommendations for dental surgical services to be moved from the
ASC Covered Ancillary Services List to the ASC CPLHCPCS Code

D1110
D1354
D2140
D2150
D2160
D2161
D2330
D2331
D2332
D2335
D2390
D2391
D2392
D2393
D2394
D2740
D2750
D2751
D2752
D2791
D2799
D2920
D2929
D2930
D2931
D2932
D2933
D2934
D2940

Nomenclature

prophylaxis - adultapplication of caries arresting medicament-per tooth
amalgam - one surface, primary or permanent
amalgam - two surfaces, primary or permanent
amalgam - three surfaces, primary or permanent
amalgam - four or more surfaces, primary or permanent
resin-based composite - one surface, anterior
resin-based composite - two surfaces, anterior
resin-based composite - three surfaces, anterior
resin-based composite - four or more surfaces or involving incisal angle(anterior)
resin-based composite crown, anterior
resin-based composite - one surface, posterior
resin-based composite - two surfaces, posterior
resin-based composite - three surfaces, posterior
resin-based composite - four or more surfaces, posteriorcrown - porcelain/ceramiccrown - porcelain fused to high noble metalcrown - porcelain fused to predominantly base metalcrown - porcelain fused to noble metalcrown - full cast predominantly base metalinterim crown-further treatment or completion of diagnosis necessaryprior to final impression
re-cement or re-bond crown
prefabricated porcelain/ceramic crown - primary toothprefabricated stainless steel crown - primary toothprefabricated stainless steel crown - permanent toothprefabricated resin crown
prefabricated stainless steel crown with resin window
prefabricated esthetic coated stainless steel crown - primary toothprotective restoration

D2941
D2950
D2951
D2952
D2954
D3110
D3120

interim therapeutic restoration - primary dentition
core buildup, including any pins when required
pin retention - per tooth, in addition to restoration
post and core in addition to crown, indirectly fabricatedprefabricated post and core in addition to crownpulp cap - direct (excluding final restoration)
pulp cap - indirect (excluding final restoration)

D3240
D3310
D3320
D3330
D3460
D3910

therapeutic pulpotomy (excluding final restoration) - removal of pulp
coronal to the dentinocemental junction and application of medicament
pulpal debridement, primary and permanent teeth
partial pulpotomy for apexogenesis - permanent tooth with incomplete
root development
pulpal therapy (resorbable filling) - anterior, primary tooth (excluding final
restoration)
pulpal therapy (resorbable filling) - posterior, primary tooth (excluding final
restoration)
endodontic therapy, anterior tooth (excluding final restoration)
endodontic therapy, premolar tooth (excluding final restoration)
endodontic therapy, molar tooth (excluding final restoration)
endodontic endosseous implantsurgical procedure for isolation of tooth with rubber dam

D4341

periodontal scaling and root planing - four or more teeth per quadrant

D3220
D3221
D3222
D3230

periodontal scaling and root planing - one to three teeth per quadrant
scaling in presence of generalized moderate or severe gingival
inflammation - full mouth, after oral evaluation
D4346
full mouth debridement to enable a comprehensive periodontal evaluationand diagnosis on a subsequent visit
D4355
localized delivery of antimicrobial agents via a controlled release vehicle
into diseased crevicular tissue, per tooth
D4381
periodontal maintenance
D4910
placement of intra-socket biological dressing to aid in hemostasis or clot
stabilization, per site
D7922©
CDT is a registered trademark of the American Dental Association.
D4342