Coding and Legislative Update Sean P. Roddy, MD Professor of Surgery Albany Medical College Albany, NY
DISCLOSURES Sean Roddy, MD No relevant financial relationship reported
Medicare Conversion Factor Total RVUs x CF = procedural payment 2016 $35.8043 MACRA 0.5% 2014 SGR patch (ABLE statute) 0.18% Radiology advanced imaging MPPR 0.07% Budget neutrality 0.013% NET CHANGE 0.24% 2017 $35.8887 2018 planned increase
CMS Proposed Mandatory Postoperative Care Reporting Major surgeries are valued based on specified # of hospital and office visits in the 90 days post-op In 2016, CMS proposed to disaggregate the 90-day global period after surgery (assumed to be inflated) Legislation overrode that proposal but requested CMS use an alternate method to identify typical postoperative care for major procedures
2017 CMS Final MPFS Rule Postoperative Care Reporting CPT code 99024 used for visits starting 7/1/2017 Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island Practices with < 10 practitioners are exempted Codes reported to CMS > 10,000 times or have allowed charges in excess of $10 million annually 34802, 34825, 35301, 36470/1, 36558, 36819, 36821, 36830, 36832, 37607, 37765, 37766 RAND also doing phone interviews to correlate data Assess the level and acuity of the visit
2017 CMS Final MPFS Rule Postoperative Care Reporting Potential only for under-reporting of the true number of post-op visits no potential for overreporting Many clearinghouses still do not accept 99024 claims so CMS may never see these submissions Uncompensated burden in those 9 states Most societies have objected to this SVS will need to monitor and react accordingly
Exercise Therapy For Claudication CMS proposed to cover supervised exercise therapy for beneficiaries with claudication Face-to-face visit with physician responsible for PAD Rx Requires: 30-60 minutes sessions comprised of a therapeutic exercise-training program Three sessions per week Up to 12 weeks of sessions Must be conducted in a hospital or outpatient hospital
Exercise Therapy For Claudication Positive: Patients may now get exercise therapy in an approved setting to assist in quality of life Negative: No current CPT code for physician oversight payment Cannot be done in a physician office setting May lead to mandatory treatment before endovascular or open surgical revascularization (similar to varicose vein coverage policies) Await publication of the CMS final rule
Vascular Lab Payments Deficit Reduction Act DRA of 2005 DRA caps office-based technical payment for ultrasound since 2007 at the lesser of: Hospital Outpatient Payment Fee Schedule versus Medicare Physicians Fee Schedule The APCs for vascular lab payments were completely overhauled for 2017 by CMS
Hospital Vascular Lab Technical APCs in 2016 Vascular Lab Ultrasound Studies 1. APC 5531 Level 1 Ultrasound and Related Services 2. APC 5532 Level 2 Ultrasound and Related Services
Hospital Vascular Lab Technical APCs in 2017 Vascular Lab Ultrasound Studies 1. APC 5531 Level 1 Ultrasound and Related Services 2. APC 5532 Level 2 Ultrasound and Related Services
Hospital Vascular Lab Technical APCs in 2017 Vascular Lab Ultrasound Studies 1. APC 5522 Level 2 Imaging without Contrast 2. APC 5523 Level 3 Imaging without Contrast
APC Ultrasound Technical Payments Limited studies 2016 APC 5531 $92.07 2017 APC 5522 $112.69 Complete studies 2016 APC 5532 $153.58 2017 APC 5523 $225.81
Vascular Lab Technical Payments CPT 2016 TC 2017 TC % Change Code Description 93880 $154 $165 7% Bilateral carotid 93970 $154 $165 7% Bilat venous extremity 93925 $154 $223 45% Bilateral LE arterial 93930 $154 $170 10% Bilateral UE arterial 93975 $154 $226 47% Complete abdominal 93990 $92 $113 23% Hemodialysis access
CPT and RUC 2017 New AAA screening CPT code Replaces the previous HCPCS G0389 code for Medicare beneficiaries
2017 AAA Screening Coding trvu trvu CPT wrvu Description -26 -TC 76706 0.55 0.79 1.87 AAA Screening U/S Subject to insurance carrier coverage limitations 2017 Medicare CF is $35.8887
CPT and RUC 2017 Mechanochemical Ablation Follows the same structure as RF and laser
2017 MOCA Coding CPT wrvu trvu facility trvu nonfacility Description 37252 1.80 2.69 39.05 MOCA, first vessel 37253 1.44 2.17 5.88 MOCA, subsequent vessel(s) 2017 Medicare CF is $35.8887
CPT and RUC 2017 Hemodialysis access diagnostic angiography and endovascular intervention Identified as potentially misvalued Nine new CPT codes were created Catheterization(s), angiography, and all endovascular intervention(s) bundled Access declots no longer assigned a 90- day global period
AV Access Imaging and Treatment Summary BASE 36901 diagnostic with no thrombectomy, no peripheral PTA or stent 36902 diagnostic + peripheral PTA 36903 diagnostic + peripheral stent +/- any peripheral PTA 36904 access thrombectomy with no peripheral PTA or stent 36905 access thrombectomy + peripheral PTA 36906 access thrombectomy + peripheral stent +/- any peripheral PTA ADD-ONs +36907 central PTA +36908 central stent +/- any central PTA +36909 embolization and all catheterization required for embolization
CPT wrvus Fac trvus NF trvus Code Description 36901 2.82 4.21 16.18 AV access angio 36902 4.24 6.27 34.41 Peripheral PTA 36903 5.85 8.58 157.80 Peripheral stent (+/- PTA) 36904 6.73 9.88 50.17 AV access declot 36905 8.46 12.40 64.20 Declot + periph PTA 36906 9.88 14.47 191.35 Declot + periph stent (+/- PTA) 36907 2.48 3.61 20.59 Central vein PTA 36908 3.73 5.41 75.84 Central vein stent (+/- PTA) 36909 3.48 5.14 55.32 AV access branch embolization 2017 MPFS values; 1 RVU = $35.8887
CPT and RUC 2017 Angioplasty outside the lower extremity Identified as potentially misvalued Includes: Aortic, upper extremity arterial, visceral artery, and venous PTA Four new codes were created bundling the procedure code and the radiology S&I Catheterization was left separately billable Mirrors the generic intravascular stent coding outside the lower extremity (eg, 37236-37239)
Angioplasty Outside The Lower Extremity New 2017 Codes CPT code 37246 Initial arterial PTA Base code CPT code 37247 Add-on code Additional arterial PTA CPT code 37248 Base code Initial venous PTA CPT code 37249 Add-on code Additional venous PTA
2017 PTA Coding CPT wrvu trvu facility trvu nonfacility Description 37246 7.00 10.29 60.60 Artery, first vessel 37247 3.50 5.10 24.52 Artery, subsequent vessel 37248 6.00 8.85 41.98 Vein, first vessel 37249 2.97 4.34 17.99 Vein, subsequent vessel 2017 Medicare CF is $35.8887
2018 Potential CPT Code Changes Infrarenal EVAR bundling Tube vs. Aorto-uni vs. Aorto-bi configurations Ruptured vs. non-ruptured Percutaneous vs open access Endovenous ablation coding additions Foam sclerosant ablations Chemical adhesive ablations
SVS APM Development Committee Ad-hoc committee designed to propose a vascular surgery specific APM for SVS members Chaired by Yazan Duwayri Representatives from Coding, Quality, and Government Relations committees Reviewing other published APMs and possible SVS APM possibilities More to come..
Conclusions Medicare CF increased by 0.24% Several vascular lab technical payments increased due to the HOPPS APC changes Significant coding changes in 2017 and 2018 New AAA screening code HD access angiography and PTA outside the LE EVAR changes and vein ablation new coding Postoperative care reporting will be required in specific states as of July 1, 2017