C9797 for Complex Embolization: What Hospitals Must Do After Pass-Through Expiration
Effective January 1, 2024, the Centers for Medicare & Medicaid Services (CMS) created HCPCS Level II procedure code C9797 for hospital outpatient departments (HOPDs) and ambulatory surgery centers (ASCs) to report complex embolization performed using the TriNav Infusion System. C9797 maps to APC 5194 (Level 4 Endovascular Procedures) with a national base payment of approximately $16,724.70 for CY 2024—comparable to what hospitals received under transitional pass-through prior to its December 31, 2023 expiration.
Successful implementation depends on hospitals updating chargemasters, retiring outdated CPT billing on the facility claim, and continuing to report the device code so CMS can maintain cost data for future rate-setting.
Coding and Reimbursement Considerations
HOPDs and ASCs should no longer report CPT 37242 or 37243 on the facility claim for procedures performed with the TriNav Infusion System. Physicians may continue to use those CPT codes on the professional claim where appropriate. These are separate billing systems, and coordination between them is essential to avoid duplicate billing and reconciliation issues.
Device code C1982, originally created for transitional pass-through payment, remains in effect for HOPD reporting even though pass-through has expired. Continued reporting allows CMS to track device-specific cost data that feeds future HOPD and ASC rate-setting. Stopping that reporting removes the cost evidence base that supports long-term appropriate payment.
Commercial payer coverage and payment policies for complex embolization vary. Confirm with each major payer whether C9797 has been loaded into claims systems, whether the procedure is covered, and whether prior authorization is required.
Critical Actions Following the C9797 Effective Date
1. Confirm Effective Date and APC Assignment
Effective January 1, 2024, HOPDs and ASCs report C9797 for complex embolization performed using the TriNav Infusion System. C9797 maps to APC 5194 with a national base payment of approximately $16,724.70 for CY 2024.
2. Update Hospital Chargemasters and Encounter Forms
Add C9797 to chargemasters and encounter forms used by interventional radiology. Confirm that CPT 37242 and 37243 have been removed from HOPD billing logic for TriNav cases. Coordinate with physician billing to ensure correct code use on each claim type.
3. Continue Reporting Device Code C1982
Report C1982 on all HOPD Medicare claims for TriNav cases. This allows CMS to track device-specific cost data that feeds future HOPD and ASC rate-setting. Suspension of C1982 reporting eliminates the data CMS needs to support continued appropriate payment.
4. Verify Commercial Payer Loading and Coverage
Confirm with each major commercial payer whether C9797 has been loaded, the procedure is covered, the device is separately payable, and prior authorization is required. Document responses and share with field reimbursement and account teams.
5. Distinguish Between Facility and Professional Claims
HOPDs use HCPCS C codes on the facility claim. Physicians may report CPT codes on the professional claim. Establish clear protocols to avoid duplicate billing, missed charges, and reconciliation issues between the two billing systems.
6. Verify Documentation Supports the Complex Embolization Code
The medical record must support use of a pressure-generating catheter and the procedural complexity distinguishing C9797 from a standard embolization. Documentation should describe the device used, target vessels, embolic agent, volume infused, and post-embolization findings.
7. Monitor Denials and Underpayments in the First 90 Days
Common issues include payers that have not loaded C9797, claims billed under retired CPT codes, missing device codes, and APC misassignment. Rapid identification allows targeted intervention before patterns spread.
8. Align Manufacturer Field and Reimbursement Teams
Manufacturers should support hospitals with billing and coding guides identifying which code to use in which setting, effective dates, and device code reporting requirements. Direct providers to verify payer policy rather than relying on vendor guidance alone.
Resources
New Technology APC Decision Tracker — CMS
Hospital OPPS January 2024 and April 2024 Updates — CMS
Disclaimer: The coding guidance and regulatory requirements described in this article are provided for general informational purposes. Coding logic and reimbursement mechanics vary by payer and setting. Hospitals and manufacturers should consult with compliance, legal, and coding counsel prior to implementing changes.
