HCPCS code E0198: Water pressure pad billing guide
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Last Updated: Oct 13, 2026
Key Takeaways
CPT code 00864 covers anesthesia for extraperitoneal lower abdomen procedures, including the urinary tract and total cystectomy (bladder removal).
CPT code 00864 carries 8 base units under the ASA Relative Value Guide; payment uses the formula (Base Units + Time Units) x Conversion Factor.
Qualifying circumstance codes 99100, 99116, 99135, and 99140 add ASA base units for CPT code 00864, but Medicare bundles them into the anesthesia payment instead of reimbursing them as separate line items.
Practice management software like Pabau helps anesthesia billing teams track documentation requirements and submit cleaner claims for codes like CPT code 00864.
CPT code 00864 is the anesthesia code for extraperitoneal procedures in the lower abdomen, including the urinary tract and total cystectomy (bladder removal).
It carries 8 base units under the ASA Relative Value Guide, one of the higher values in the 00800–00882 family. That is why the base unit count is often the first thing payers check on a cystectomy claim.
Cystectomy anesthesia claims still get denied or underpaid more often than coders expect, usually because of incomplete time documentation or a missing qualifying circumstance code. Here is how the base units, Medicare payment math, and documentation rules for CPT code 00864 actually work.
The American Medical Association (AMA) publishes and maintains the CPT code set, including all anesthesia codes in the 00100-01999 range. Code 00864 falls within the lower abdomen family (00800–00882), which covers anesthesia for extraperitoneal and intraperitoneal procedures in this anatomical region.
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What CPT code 00864 actually covers
The official AMA long descriptor for CPT code 00864 reads: “Anesthesia for extraperitoneal procedure(s) in lower abdomen including urinary tract; total cystectomy.” The code is exclusively for extraperitoneal lower abdomen work; it does not extend to intraperitoneal upper abdomen procedures.
In practice, CPT code 00864 applies to anesthesia for total cystectomy and other extraperitoneal procedures involving the urinary tract in the lower abdomen. Cystectomy for bladder cancer is the most common surgical context for this code.
CPT code 00864 carries 8 base units under the ASA RVG
The base unit value assigned to a procedure code reflects the clinical complexity, risk, and skill required for that anesthetic service. For CPT code 00864, the base unit value is 8, per the ASA Relative Value Guide. Base unit values are revised annually, so always confirm the current ASA RVG or the CMS Physician Fee Schedule before submitting claims.
How anesthesia billing is calculated
Anesthesia payment does not follow the same relative value unit (RVU) formula used for other CPT codes. Instead, payers use a base-plus-time formula defined in the CMS Medicare Claims Processing Manual, Chapter 12:
Payment = (Base Units + Time Units) x Conversion Factor
Time units are typically calculated at one unit per 15 minutes of anesthesia time. So a 90-minute cystectomy generates 6 time units. With a base unit value of 8, total billed units equal 14 before qualifying circumstances are added.
The Medicare conversion factor for anesthesia services varies by geographic locality and clinician QP (Qualifying APM Participant) status, and is updated annually by CMS. Use the FastRVU 2026 lookup tool or the CMS fee schedule search to confirm current locality-specific rates before calculating expected reimbursement for CPT code 00864.
Pro Tip
Always document anesthesia start and stop times in the operative record. Payers audit time units frequently for high-complexity codes like CPT code 00864. Missing or inconsistent time documentation is the leading cause of claim downcoding on cystectomy anesthesia claims.
How Medicare pays for CPT code 00864
Medicare is the dominant payer for cystectomy procedures, given the age profile of bladder cancer patients. Payment rates for CPT code 00864 under Medicare depend on three factors: the base unit value, total anesthesia time, and the locality-specific conversion factor published in the annual Medicare Physician Fee Schedule (MPFS).
Rates differ significantly across geographic regions. A claim for the same 90-minute cystectomy anesthesia case can reimburse at different levels in California versus rural Mississippi, so cross-check the locality-specific rate against your MAC (Medicare Administrative Contractor) fee schedule before quoting expected payment to anesthesia providers.
CRNA billing, physician anesthesiologist billing, and medical direction scenarios each follow distinct reimbursement rules under CMS. For CRNA-only cases, the modifier QZ (CRNA without medical direction) typically allows 100% of the allowed amount. Medical direction scenarios use modifiers QK and QX, splitting the payment between the supervising physician and the CRNA.
Never conflate these billing pathways on the same claim.
Qualifying circumstances that affect CPT code 00864 payment
Four add-on qualifying circumstance codes can increase the ASA base units billed alongside CPT code 00864 when specific clinical conditions are present. Each one requires documented clinical justification in the anesthesia record, not just a code on the claim form.
Code 99100 applies most frequently with CPT code 00864, since bladder cancer predominantly affects patients over 70. Document the patient’s age explicitly in the anesthesia record. Codes 99116 and 99135 are mutually exclusive and require clear clinical notes from the anesthesiologist describing the technique used.
Under Medicare, these codes carry a status indicator of B. That means they are bundled into the primary anesthesia payment, not reimbursed as separate line items, even though the ASA RVG assigns each one its own base unit value.
Separate payment depends on the payer’s own policy; UnitedHealthcare, for example, also bundles them.
ICD-10 codes commonly paired with CPT code 00864
Medical necessity for CPT code 00864 must be supported by an appropriate ICD-10-CM diagnosis code on the claim. The diagnosis has to match the documented reason for the cystectomy or urinary tract procedure; related findings.
The table below lists the most commonly paired diagnosis codes for cystectomy anesthesia claims.
Always use the most specific ICD-10-CM code available. “Unspecified” codes (C67.9) are acceptable when the operative report does not document a more specific site, but site-specific codes (C67.0 through C67.8) reduce medical necessity audit risk. The same specificity principle applies to adjacent urinary diagnoses like R33.9: the more precise the diagnosis, the stronger the claim. Batch submissions group many claims into one claim file, and one malformed record can hold up the batch. A payer reviewing this code looks for the reasoning in the note, not only the conclusion, so the documentation level matters.
Practices that treat overlapping pelvic floor and urinary tract conditions alongside cystectomy patients sometimes rely on pelvic health software to keep diagnosis history and care plans in one record.
Reduce anesthesia claim denials with better documentation tracking
Pabau helps surgical and anesthesia billing teams manage pre-anesthesia evaluations, intraoperative records, and post-anesthesia notes in one place, so claims for codes like CPT code 00864 go out clean the first time.
Related CPT codes in the 00800–00882 range
CPT code 00864 sits within the lower abdomen anesthesia code family. Choosing the wrong sibling code is a common coder error, particularly when the procedure involves adjacent anatomical structures. The table below compares the most frequently confused codes in this range.
Consult the AAPC CPT code lookup to verify descriptions against your operative report.
CPT code 00860 carries 6 base units, two fewer than CPT code 00864’s 8. Using 00860 when the procedure was actually a cystectomy does not just raise audit exposure. It changes the reimbursement amount itself, since the base-plus-time formula multiplies a lower base unit figure.
For context.
Billing and documentation requirements for CPT code 00864
Documentation requirements for anesthesia codes are more detailed than for most surgical CPT codes. CMS and the American Society of Anesthesiologists (ASA) require specific record elements for every claim involving CPT code 00864. Missing any one of these is enough to trigger a claim denial or a post-payment audit recovery.
- Pre-anesthesia evaluation: Completed and signed by the anesthesiologist or CRNA before the procedure begins. Must document patient health history, ASA physical status classification, and planned anesthetic technique.
- Intraoperative anesthesia record: Continuous record of vital signs, anesthetic agents, time in and time out, and any significant clinical events. Time documentation is essential for accurate unit calculation.
- Post-anesthesia note: Completed within the timeframe required by facility policy, documenting patient’s condition on transfer from the operating room and any immediate post-operative complications.
- Attending anesthesiologist signature: Required for medical direction claims (modifiers QK, QX). For CRNA independent billing (QZ), the CRNA’s own documentation and signature suffice.
- Qualifying circumstance documentation: If reporting 99100, 99116, 99135, or 99140 alongside CPT code 00864, the clinical basis for each must appear in the anesthesia record, not just on the claim form.
Use claims management software to build documentation checklists into the pre-submission workflow. Catching missing fields before claim submission is far less costly than responding to a payer’s request for records post-payment.
When propofol or other anesthetic agents are billed separately from the professional anesthesia service, such as a facility charge under a drug code like J2704, keep the drug administration record separate from the anesthesia time record used for CPT code 00864.
ASC vs. hospital billing for CPT code 00864
Radical cystectomy is predominantly performed in inpatient hospital settings, which affects how the facility and the anesthesia provider each bill for the service.
In a hospital inpatient setting. The facility bills the room, nursing, and equipment costs separately on a UB-04 form. These claims are adjudicated independently.
In an ambulatory surgical center (ASC), the facility fee is governed by the CMS Outpatient Prospective Payment System (OPPS). Not all cystectomy procedures qualify for ASC settings, given their complexity and inpatient recovery requirements. Check the CrossCoder crosswalk tool and the CMS ASC Approved Procedure List before scheduling a cystectomy in an ASC environment.
Anesthesia billing under CPT code 00864 follows the same base-plus-time formula regardless of facility setting. The ASC status indicator affects facility payment, not the professional anesthesia claim.
Urology practices performing cystectomies, especially those also running outpatient men’s health services.
Pro Tip
Verify ASC eligibility before scheduling cystectomy procedures. CMS updates the ASC Approved Procedure List annually. If a radical cystectomy appears on a claim billed from an ASC that is not approved for the procedure, the entire claim, including the CPT code 00864 anesthesia component, risks denial.
The bottom line on CPT code 00864 billing
Claims for CPT code 00864 are denied most often for three reasons: incomplete anesthesia time documentation, missing qualifying circumstance codes, and incorrect CRNA versus physician modifier assignment. Each is preventable with structured pre-submission review.
Pabau helps anesthesia and surgical billing teams build those documentation checklists, track claim status, and reduce denial rates on high-complexity codes such as CPT code 00864.
If cleaner claims and fewer denials sound useful for your billing team, book a demo to see how it works.
Continue your research
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Billing anesthesia for a cesarean delivery? 01961 explains base units and modifiers specific to cesarean anesthesia.
Related CPT codes
- CPT code 00731 — Anesthesia billing for upper GI endoscopy
- CPT code 00866 — Adrenalectomy anesthesia
- CPT Code 00872 — Anesthesia for lithotripsy with water bath
- CPT code 00873 — Lithotripsy Anesthesia
Frequently asked questions
What modifier applies for CRNA-only anesthesia billing on CPT code 00864?
Use modifier QZ when a CRNA provides anesthesia without physician medical direction; it allows 100% of the allowed amount. Medical direction cases use modifiers QK and QX, splitting payment between the physician and the CRNA.
Does CPT code 00864 apply to laparoscopic or robotic cystectomy?
Yes. CPT code 00864 is defined by anatomical location and approach category, not by whether the surgeon operates open, laparoscopic, or robotic. It applies to anesthesia for all three approaches to cystectomy.
Who bills the surgical part of a cystectomy separately from CPT code 00864?
The anesthesiologist or CRNA reports CPT code 00864 for the anesthesia service. The surgeon reports a separate surgical CPT code for the operation itself, and the two claims are billed and adjudicated independently.
Are qualifying circumstance codes paid separately under Medicare for CPT code 00864?
No. Medicare gives qualifying circumstance codes like 99100 and 99135 a status indicator of B, so they’re bundled into the anesthesia payment rather than paid as separate line items, even though the ASA RVG lists base units for each.
What is the difference between CPT code 00864 and CPT code 00862?
CPT code 00864 covers extraperitoneal lower abdomen procedures, including the urinary tract and cystectomy. CPT code 00862 covers renal procedures in the same code family. Confirm the operative report names the correct organ first.
Does CPT code 00864 include recovery room or PACU time?
No. CPT code 00864 and its time units cover the anesthesia service itself, from preparation through the end of anesthesia care. Post-anesthesia care unit monitoring is billed separately by the facility.
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