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Sept. 2, 2025
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From the Chair of the Commission on Economics

Frank  J. Rybicki MD, PhD, FACR

 

Frank J. Rybicki MD, PhD, FACR

Chair of the ACR Artificial Intelligence Economics Committee and Department of Radiology at Banner University Medical Center & University of Arizona — Phoenix

Guest Columnist


A 2025 Healthcare Common Procedure Coding System code opens new options for billing for these emerging services. Here’s how to begin using it in your practice.

In part one of this two-part series, we introduced the new code for anatomical segmentation imaging (C8001) for surface mesh files.

Historically, digital manipulations that begin and end with the .dcm file extension (multiplanar reformatted images, maximum/minimum intensity projections and DCM volume rendering) have been coded with CPT 76376 and 76377, which are paid under the Medicare Physician Fee Schedule at the following rates:

Code  Description  Total Payment  Professional Component  Technical Component 
 76376 3D rendering with interpretation and reporting of CT, MR imaging, ultrasound or other tomographic modality with image postprocessing under concurrent supervision; requiring image postprocessing on an independent workstation  $24.91  $9.06  $15.85
 76377 3D rendering with interpretation and reporting of CT, MR imaging, ultrasound or other tomographic modality with image postprocessing under concurrent supervision; not requiring image postprocessing on an independent workstation
 $76.98  $36.23  $40.76


Codes 76376 and 76377 are not paid separately under the Hospital Outpatient Prospective Payment System (HOPPS) system, as they are bundled into payment for other services.

Which Patient Use Cases Are Applicable

As noted in part one, surface mesh files are common very-high-value digital medical assets. DCM data is sufficient for diagnosis and procedure planning for most cases. However, for a small-but-growing fraction of patients, surface mesh files are an essential part of their care. Surface mesh files are created from Digital Imaging and Communications in Medicine (DICOM) data, and these file formats (.stl,.obj, etc.) enable digital manipulations that are not compatible with data in DCM format. Until recently, practices relied on outside vendors to convert DCM files to a new surface mesh file called Final Anatomic Representation.

Radiologists are now becoming very engaged in these digital medical assets and are bringing some of these services in house. The uses for Final Anatomic Representation are categorized as follows:

  1. 3D PDF
  2. Extended reality
  3. Computational analyses (finite element analyses and computational fluid dynamics)
  4. Artificial intelligence
  5. 3D printing

CMS created the new Healthcare Common Procedure Coding System (HCPCS) code C8001 for the 3D anatomical segmentation. In the April update, CMS revised the Ambulatory Payment Classification (APC) placement from APC 5521 to APC 5721, with a notable increase in corresponding reimbursement to $156.46. If hospitals report the actual costs of providing services for C8001 on their claims reporting to CMS, these cost data will inform a stronger case to argue for a higher APC placement in the future since CMS always defaults to the claims data for rate setting. Collecting more adequate reimbursement would be expected to expand patient access to these services.

How HCPCS Code C8001 Can (and Cannot) Be Used

First, consider the five categories of clinical use for Final Anatomic Representation above. C8001 can and should be utilized for creating a surface mesh file Final Anatomic Representation from DICOM data for patients who need all of these services, except for the last category (surface mesh files that are 3D printed).

The codes that currently exist to report 3D printing services within the HOPPS are as follows:

Code  Description  Status Indicator  Ambulatory Payment Classification  Payment Rate 
 0559T Anatomic model 3D printed from image dataset(s): first individually prepared and processed component of an anatomic structure
 Q1 5733 — Level 3 Minor Procedures  $59.40
 +0560T Anatomic model 3D printed from image dataset(s); each additional individually prepared and processed component of an anatomic structure
 N  *  *
 0561T Anatomic guide 3D printed from image dataset(s): first anatomic guide
 Q1 5733 — Level 3 Minor Procedures
 $59.40
 +0562T Anatomic guide 3D printed from image dataset(s): each additional anatomic guide
 N  *  *

Status indicator Q1 = conditionally packaged; may be subject to separate payment.
Status indicator N = payment is packaged into payment for other services.
*Add-on codes are not separately paid under the HOPPS system. There is no separate APC payment.

There are other intriguing potential ramifications of C8001; these arise because the code description does not specify a file type. Despite the growth in the use of surface mesh files, most procedures can still be planned by using DICOM data alone, so it is important to reconsider traditional 3D renderings given the new coding opportunity. Specifically, hospitals could cease reporting code 76376 and 76377 and instead report C8001 to collect the HOPPS reimbursement of $156.46.

One rationale for this strategy is that the total reimbursement is higher, despite there being no payment for the professional component in HOPPS. Should this occur, the hospital claims reporting data submitted to CMS will show a higher uptake of C8001 and continued low utilization of the historical codes, possibly leading to 76376 and 76377 naturally phasing out. While this in and of itself generates some risk for overall payments, the reward of proactively resetting the bar for complex patients and for claiming leadership in reimbursement for these patients is appealing.

There are nuances to this strategy. Particularly, outpatient non-hospital-affiliated radiology groups who own their own equipment cannot bill CMS for technical payments in the OPPS setting. In this case, this strategy would only benefit radiologists who are affiliated with a hospital. ACR continues to monitor and advance reimbursement for the portfolio of 3D services as generated from DICOM data.

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