The Centers for Medicare and Medicaid Services (CMS) released their proposed rule for Medicare Physician Fee Schedule (MPFS), which outlines payment and regulatory decisions for year 2015.
ISIS staff is currently reviewing the rule in detail to determine responses, but some issues of particular importance to ISIS members are:
· CMS Proposal to Bundle Imaging Guidance with Epidural Injection Codes
After implementing severe payment cuts to the epidural codes in year 2014, CMS acknowledges receiving a significant number of comment letters. After reviewing the issue in more detail, CMS proposes in the current rule that imaging guidance should be included in CPT codes 62310, 62311, 62318 and 62319 and is referring the codes as potentially misvalued, and to be reviewed again by the Relative Value Update Committee (RUC). In the meantime, in the year 2015 CMS plans to base payment for these codes on the 2013 work RVUs and direct practice expense inputs.
· Neurostimulator Codes – Values to be Reviewed
§ 64553 (Percutaneous implantation of neurostimulator electrode array; cranial nerve)
§ 64555 (Percutaneous implantation of neurostimulator electrode array; peripheral nerve (excludes sacral nerve))
In response to a stakeholder question regarding whether the above codes include proper non-facility practice expense, CMS stated that the codes have not been evaluated in quite some time and will be placed on a potentially misvalued code list for review by the RUC.
ISIS will be involved in the review of values for both ESI and Neurostimulator codes at the RUC. ISIS is the only interventional pain organization with consistent involvement: our volunteers and staff attend every meeting and work to assure the most optimal results in the valuation of spine intervention codes. This is extremely important due to the fact that when CMS refers codes to the RUC as potentially misvalued, they are most likely to have their values lowered.
For more information on the CMS’ Proposed Payment Rule please click here.