HCPCS code C1841 – Device billing under OPPS

Key takeaways

HCPCS Code C1841 described a retinal prosthesis, including all internal and external components, the device in the Argus II system.

CMS deleted C1841 and its add-on code C1842 effective January 1, 2023, so neither code is valid for later dates of service.

C1841 held OPPS transitional pass-through status from October 1, 2013 to December 31, 2015, and its cost was packaged after that.

CMS named no replacement code, and it reported in 2022 that the Argus II device was no longer available.

Use C1841 only for dates of service on or before December 31, 2022, such as corrected claims, reopenings and audits.

HCPCS Code C1841: official descriptor and status

HCPCS Code C1841 is a deleted C code in the HCPCS Level II system. Its long descriptor reads: Retinal prosthesis, includes all internal and external components. The device it described was the Argus II Retinal Prosthesis System.

The CMS alpha-numeric HCPCS file lists C1841 with action code D, which means deleted. Its termination date is December 31, 2022. The add-on code C1842 carries the same action code and the same termination date.

A deleted code stays in the HCPCS file for reference, which is why C1841 still appears in current lookups. Its presence there does not make it billable for a current date of service.

History of C1841: from pass-through to deletion

CMS created C1841 for the Argus II system and granted it transitional pass-through status beginning October 1, 2013. That status expired on December 31, 2015.

From 2016, CMS assigned C1841 status indicator N, which means its payment is packaged. The device cost was paid through the implant procedure, CPT 0100T, which CMS placed in a New Technology APC. For 2016, that APC paid $95,000 for the procedure and the device together.

For 2017, CMS added C1842 to fix claims processing for ambulatory surgical centers (ASCs). ASCs reported C1842 alongside C1841 and 0100T, and CMS split its device payment equally between the two device codes.

In its July 2022 ASC update, CMS said the Argus II device was no longer available in the marketplace. It added that hospital outpatient departments and ASCs no longer performed the implant procedure. CMS changed the ASC payment indicators for 0100T, C1841 and C1842, and both device codes were deleted effective January 1, 2023.

Each of those dates changed how a C1841 line was paid, and the timeline below sets the periods side by side.

OPPS reimbursement for C1841 by date of service

How Medicare paid for the device depends entirely on the date of service. The table below sets out the three periods. Confirm figures for any historical claim in the OPPS Addendum B for that calendar year.

Pass-through status: when it ended for C1841

Transitional pass-through payment is a temporary OPPS mechanism for new devices whose costs are not yet reflected in APC rates. Under 42 CFR 419.66, a device keeps pass-through status for at least two years and no more than three.

For C1841, that period ran from October 1, 2013 to December 31, 2015. The code then stayed valid for reporting, but its cost was packaged into the procedure payment. Deletion on January 1, 2023 ended its use altogether.

Billing retinal prosthesis claims on or after January 1, 2023

A deleted code is not valid for a date of service after its termination date. Expect a line carrying C1841 or C1842 for 2023 or later to come back as an invalid HCPCS code.

CMS named no replacement code, so do not substitute another device C code. C1840, for example, describes a telescopic intraocular lens, which is a different device entirely.

In practice, the question rarely comes up. CMS reported in 2022 that the device was off the market and that the implant procedure was no longer performed.

If a retinal prosthesis claim does arise, check the current OPPS Addendum B status indicator for CPT 0100T. Then ask your Medicare Administrative Contractor (MAC) how to report the device before you submit.

Patients implanted before 2023 may still need device follow-up. Category III codes 0472T and 0473T describe initial programming and reprogramming of an intraocular retinal electrode array. Confirm their current status and payment in Addendum B before you bill them.

Correcting and appealing claims dated before 2023

C1841 remains the correct code for dates of service from October 1, 2013 through December 31, 2022. You may still meet it in reopenings, appeals, audits and corrected claims. Always report the code that was valid on the date of service, not the code set in force today.

• Timely filing has passed: Medicare allows 12 months from the date of service to file. For every C1841 date of service, that window has closed, so changes now run through reopenings and appeals.
• Hospital outpatient claims: C1841 was reported on the institutional claim with CPT 0100T on the same claim, under the rules for that date of service.
• ASC claims from 2017: C1842 was reported with C1841 and 0100T. CMS split its device payment equally between the two device lines.
• Packaged years, 2016 to 2022: C1841 received no separate payment. Reporting it still put the device cost on the claim.
• Device credits: a device received at no cost, or with full or partial credit, took modifier FB or FC under that year’s rules.

A corrected claim still has to pass the payer’s front-end edits, so the rules for clean claim submission apply to it as well.

Documentation for historical C1841 claims

Audits and appeals on pre-2023 claims rest on the clinical record. Keep these documents together for every C1841 claim still open to review.

• Operative note: it names the device implanted and describes the procedure reported with 0100T.
• Implant log: it records the manufacturer, model and serial or lot number, matching the device billed.
• Physician order: it authorizes the procedure before the date of service.
• Medical necessity: the record supports the diagnosis codes on the claim. Check any applicable coverage policy in the Medicare Coverage Database.
• Acquisition cost record: the invoice traces the charge to the purchase, and it shows any device credit received.

Codes related to HCPCS Code C1841

C1841 belongs to a small group of retinal prosthesis codes. Neighboring device C codes sit in our HCPCS code library. Check the HCPCS quarterly update file for current descriptors and status.

Payer policies for retinal prosthesis claims

• Medicare: check the Medicare Coverage Database for any national or local coverage policy that applied on the date of service.
• Commercial payers: each plan keeps its own retinal prosthesis policy. Blue Shield of California, for example, noted the C1841 and C1842 deletions in its 2023 policy update.
• Medicaid: state programs set their own device rules. Confirm with the state fee schedule or the managed care plan’s billing guide.

How Pabau keeps retired codes off your claims

Code deletions trip up practices when an old code lingers in a fee schedule or a claim template. In Pabau’s practice management software, each service carries the codes you bill for it, so a retired code is easier to find and replace.

In the US, Pabau’s claims management software submits claims built from the data already in your patient records, and tracks each claim’s status. A rejected line shows up early, rather than weeks later in an aging report.

Pabau is built for outpatient practices rather than hospital billing departments. For practices working through rejections, the guide to denial management in healthcare covers how to group them by root cause.

Submit and track every claim from one system

Pabau’s claims management software submits claims from the data in your patient records and tracks each one’s status. Rejections surface early, so your team can fix them fast.

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Conclusion

C1841 is closed to new claims. CMS deleted it with its add-on C1842 on January 1, 2023, after the Argus II device left the market, and named no replacement.

The code still matters for one job: getting pre-2023 history right. Match the code to the date of service, keep the implant record, and check Addendum B before any later retinal prosthesis claim.

Book a demo to see how Pabau helps your practice submit and track claims built from accurate patient records.

Continue your research

Reconciling an ASC claim from 2017 to 2022? HCPCS Code C1842 covers the add-on code reported with C1841 on ASC claims.

Need a broader grounding in HCPCS billing structure? Medical billing fundamentals explains how HCPCS Level I and Level II codes interact with payer claim processing.

Seeing repeat denials across your device claims? Denial codes in medical billing maps the most common CARC reason codes to their root causes and resolution steps.

Want to reduce prior-auth delays on outpatient procedures? Insurance eligibility verification covers how to confirm a patient’s benefits before the procedure date.

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