Changes to Medicare Physician Fee Schedule Rates

The summary of events and newsworthy items for the month of October is provided on the following pages. In most instances, the link to the full document of information is provided. Any of the contents may be further discussed by reaching out to Revenue Cycle Coding Strategies Inc.

ACR and ASTRO Team Up to Update Radiation Therapy Guidelines

The American College of Radiology and American Society for Radiation Oncology (ASTRO) are working togetherto update parameters for radiation therapy for clinicians. Both entities have separately maintained guidelines relative to radiation therapy procedures on theirrespective websites. A total of seven practice parameters were updated and the focus was to ensure safety of the administered radiation specific to the practice area.

ACR and ASTRO developed three of the parameters (select parameter to follow to link):

  • Performing stereotactic body radiation therapy
  • Image-guided radiation therapy
  • Communication guidelines for radiation oncologists

Four other parameters were updated with input by American College of Nuclear Medicine (ACNM), the Society of Nuclear Medicine and Molecular Imaging (SNMMI), the American Brachytherapy Society (ABS), the Society for Pediatric Radiology (SPR) and the Society of Interventional Radiology (SIR)as they relate to use of radioactive materials.

The following are the parameters updated, (select parameter to follow to link):

  • •Performing therapy using unsealed radiopharmaceutical sources
  • Performing therapy when using Radium-223
  • Treating benign and malignant thyroid disease using I-131 Sodium Iodide
  • Practice parameter for selective internal radiation therapy or radioembolization using microsphere device brachytherapy device in patients with liver malignancies

ASTRO has several documents available on their website under Consensus Documents, this includes the recent parameter updates and a link to the Model Policies.

https://www.astro.org/Patient-Care-and-Research/Clinical-Practice-Statements/Consensus-Documents

https://www.astro.org/Daily-Practice/Reimbursement/Model-Policies

Proposed Rule Changes to Stark Law

In conjunction with the Patients over Paperwork initiative, CMS issued a proposed rule on October 9, to update and clarify the Medicare physician self-referral law, also known as the “Stark Law”.The rule hashad no noteworthy updates since it was enacted in 1989. The proposed rule aims to reinforce the Stark Law’s objective of protecting patients from unnecessary services and being steered to less convenient, lower quality, or more expensive services because of a physician’s financial self-interest while supporting the Patients over Paperwork initiative by reducing burdensome regulatory guidelines on physicians and other health care providers. To ensure patients receive the highest quality of care, the proposed rule allows physicians and other health care providers to coordinate care across various health care settings.

The proposed rule, in its entirety, can be found here. 

Medicare Executive Order to Expand Medicare Advantage

At the direction of an Executive Order on October 3, 2019, CMS has been instructed to facilitate the expansion of Medicare Advantage by exploring regulations that would provide more diverse and affordable planchoices for beneficiaries. The order also directs HHS Secretary Alex Azar to collaborate with the acting chairman of the White House Council of Economic Advisors, Tomas Philipson to submit a report with proposed regulation that will reduce physician burden and allow providers to spend more time with patients. Eliminating arduous billing requirements, supervision requirements, and conditions of participation were some of the suggested actions Azar investigate to reduce physician burden. Azar is also taskedwith proposing modifications in fee-for-service Medicare payments to encourage price competition. The order also encompassesrewarding care through site neutrality, improving the availability and quality of cost data, protection of beneficiaries and taxpayers by eliminating waste, fraud, and abuse, and encouraging medical innovation by streamlining the coding and coverage process.

ACR Encourages CMS to Reevaluate Changes to E/M Coding for 2021

The American College of Radiology (ARC) and the Radiology Advocacy Network (RAN) are encouraging Congress to reevaluate the potential impact to the specialty of radiologyregardingthe proposed change in reimbursement by CMS to evaluation and management (E/M) codes. With the proposed rule of increasing payment for E/M codes in 2021, CMS estimates that the proposed increase would result in an 8% payment decrease to radiology, which as a specialty, does not commonly bill E/M codes. However, outside, independent research indicates the decrease would be closer to 9% or roughly, $452 million a year to diagnostic radiology services. Although there has been an increase in overall diagnostic radiology services delivered, there has been a decrease in payment from 2006 to 2017 from previous CMS and Congressional policy changes.

ACR Presents Codes to RUC for Valuation

The American College of Radiology presented 5 codes at the October 2019 RUC Meeting for future valuation. The Relative Value and Update Committee sets works with CMS to value codes under the Medicare Physician Fee Schedule (MPFS). Recommendations for valuation by the RUC are evaluated by CMS at rule time to establish the rates and values of the designated CPT®codes.

The following code families were discussed as part of the meeting:

  • Diagnostic and Screening CT of the Chest
  • Medical Physics Dose Evaluations

ACR has also announced they will be disseminating surveys toarandom sampleof ACR membership for the January 2020 RUC meeting. Two of the surveys “pertain to physician work related to radiologic examination of the eye and venography. The third, a multi-specialty survey, will be circulated by the Society of Interventional Radiology. It will focus on the practice expense involved in medical physics dose evaluation.”

Turvey data will be collected and presented to CMS for consideration in the MPFS CY 2021 ruling.

AMA CPT® Editorial Panel Releases September Meeting Summary

On October 25ththe AMA CPT® Editorial Panel released the September Meeting summary notes. The following are a few of the changes noted. The full summary can be found at https://www.ama-assn.org/system/files/2019-10/september-2019-summary-panel-actions.pdf.

  • Chronic Care Management Revisions
    • Revisions to codes 99487, 99489, and 99490
    • New code994XX
    • Accepted revisionof the Digitally Stored Data Services/Remote Physiologic Monitoring guidelines; revision of the Chronic Care Management Services guidelines;
    • Revision of 99490 to specify time spent; addition of add-on code 994XX to report additional time;
    • Revision of the Complex Chronic Care Management Services guidelines;
    • Revision of codes 99487, 99489 to remove reference of the requirements; and
    • Revision of the Home and Outpatient International Normalized Ratio (INR) Monitoring Services guidelines
    • Effective January 1, 2021
  • Posterior Lumbar Arthrodesis and Decompression –Postponed
  • Arthroscopic Removal of Loose Body Guidelines
    • Accepted addition of introductory guidelines in the Endoscopy/Arthroscopy subsection to provide uniformity across the codes and to clarify appropriate code usage within the CPT®code set
    • Effective January 1, 2021
  • Pacemaker-Defibrillator Table Heading Revision
    • Accepted editorial revisionto the table heading under Pacemaker/Implantable Defibrillator section
    • Effective January 1, 2021
  • Medication Therapy Management Services –Rejected
  • Definition of Face-to-Face –Withdrawn
  • Parenthetical Revision –EVAR
    • Issue #1 -Rejected
    • Issue #2-Accepted revision to the parenthetical following code 34709 (Errata or Technical Correction)
    • Issue #2: January 1, 2020

October Coding Corner

Within this section, current topics will be the focus.  In some cases, the Q&A could reflect common questions received by Revenue Cycle Coding Strategies Inc. and in other cases, represent current issues encountered by Revenue Cycle Coding Strategies Inc. professionals.

Question: When Physics does their weekly chart check/questionnaire after every 5th treatment, does the charge (77336) have to match the date of the 5th treatment exactly? Or can it be within the week?

Advice: The physics chart check must be completed once within every five fractions of treatment. Generally, there are two ways to apply the charge; on the day of the actual chart check or on every fifth fraction. If the check does not happen within the five fractions, it is not billable.

Question: Regarding CPT®36415, is the it correct to bill itwith a laboratory code or is the venipuncture inclusive to the laboratory charge?

Advice: Per CPT®Assistant: “The collection of the specimen by venipuncture is not considered an integral part of the laboratory procedure performed. If both the collection of the specimen(s) by venipuncture and the laboratory procedure(s) are performed, then it would be appropriate to report a code for the collection of the specimen(s) in addition to the appropriate code(s) from the 80000 series for the laboratory procedure(s) performed.”