Bundling of 64447 in 36620

I have run into an issue that I am getting conflicting information on, Medicare states, and I have found it on their website, that 36620 includes 64447 under ALL situations and you cannot bill both procedures on the same date for any reason. Modifiers and diagnosis codes will not affect the denial as unbundling with Medicare selecting the 36620 a much cheaper procedure over 64447 to pay on. On the other hand, by boss spoke with a consultant who stated that it should be billable. Does anyone else have this issue? My thinking would be to drop the 36620 from the claim and just bill for the 64447 but, isn't not billing for a service also a problem if you were to be audited?

CCI edits

I cannot find an edit. I am not sure if I am missing it but if there is no edit then there is no problem. It should be able to be billed together.
Did anyone else help you on this?

Bundling of 64447 in 36620

No one else has replied so far, I would be content with Medicare's reply, it is clearly in black and white on their website that these are bundled and not modifier applicable, but my boss's boss, consulted a consultant and according to them, it can be billed as long as you put down a new ICD-9 code, which Medicare denied asap. I just need to find something definitive that states it in such a way that they get it through their rather dense dural cover that this isn't a doable code combination no matter how you try to fix it up. But at the same time, they are getting hives worrying that by coding for the 64447 and not mentioning the 36620 may cause them an audit issue in the future, as Medicare isn't stupid and has included a much more expensive procedure in a cheaper code to save money, not to really make coding more accurate or easier.

Medicare website

Where did you find it on their website? I would like to see that. Thank you

Bundling of 64447 in 36620

Here is the list of links I had to use CMS Home > Medicare > National Correct Coding Initiatives Edits > NCCI Edits - Physicians and then look up the code range, don't worry about what speciality it may be.

Edit errors

I just read an article from the American Society of Anesthesiologists regarding this topic. There was an error on the CCI file with the April update that will be corrected on October 1. Unfortunately, Medicare will continue to deny these codes until then. If you hold on to the claim until 10/1 it should pay correctly