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|Coding and Reimbursement|
Appropriate coding is more important than ever. The International Spine Intervention Society encourages its members to assure that they and their billing staff are reporting the correct CPT codes for services performed. In case of radiofrequency neurotomy, since January 2012, the codes should be reported per facet joint not on a ‘per nerve’ basis. The codes also include imaging guidance, which should not be coded separately.
For more information, click HERE.
The Centers for Medicare and Medicaid Services (CMS) is establishing four new Healthcare Common Procedure Coding System (HCPCS) modifiers to define subsets of the -59 modifier, a modifier used to define a “Distinct Procedural Service.” The new modifiers will go into effect as of January 1, 2015 and are as follows:
For more information, please see the original document from CMS, available HERE.
CMS Proposal to Bundle Imaging Guidance with Epidural Injection Codes (July 16, 2014)
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.
ICD-10 Deadline Set to October 1, 2015
The U.S. Department of Health and Human Services (HHS) finalized October 1, 2015 as the new compliance date for health care providers, health plans, and health care clearinghouses to transition to ICD-10, the tenth revision of the International Classification of Diseases. This deadline allows providers, insurance companies, and others in the health care industry time to ramp up their operations to ensure their systems and business processes are ready to go on October 1, 2015. For more information, view the press release.
CMS Proposed Physician Payment Rules for 2015 (July 16, 2014)
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. Some issues of particular importance to the Society's members are:
CMS Proposal to Bundle Imaging Guidance with Epidural Injection Codes (July 16, 2014)
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 (July 16, 2014)
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.
The International Spine Intervention Society will be involved in the review of values for both ESI and Neurostimulator codes at the RUC. The International Spine Intervention Society 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 visit: https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-15948.pdf.
Medicare Appeals Backlog Sign-on Letter (February 25, 2014)
The International Spine Intervention Society has joined numerous specialty and state medical societies in a letter to the Department of Health and Human Services (HHS) Office of Medicare Hearings and Appeals (OMHA) expressing concern about the backlog of Medicare appeals. The letter urges OMHA "to develop a comprehensive solution to the Medicare backlog problem so that appealed cases may be assigned and adjudicated without delay.” To see the letter, click HERE.
Epidural Cuts 2014 (February 25, 2014)
The International Spine Intervention Society submitted a letter to CMS outlining concerns with CMS' methodology for assigning work values to the codes and requesting a review by a refinement panel. For more information, click HERE.
International Spine Intervention Society Submits Comments to CMS on 2014 Payment Regulations - Epidural Cuts and Fluoroscopy Guidance (February 25, 2014)
On January 27, the International Spine Intervention Society submitted comments to CMS regarding the revisions to payment policies under the physician fee schedule for CY 2014. The Society strongly opposed CMS' proposed rationale for cutting values of interlaminar injections and is requesting that CMS convene a Refinement Panel to review CMS' decision. The Society had requested and successfully participated in a refinement panel in the past to raise the work value of the transforaminal epidural code. Additionally, in response to CMS' comments questioning fluoroscopy guidance values, the Society asserted that the physician work time and value are appropriate for the spine imaging guidance code. To see the Society's comment letter, click here. The International Spine Intervention Society also collaborated with multiple pain societies in submitting an additional letter expressing concerns with the cuts to the epidural interlaminar procedures and calling on CMS to revert to the previous values, until the process is finalized. The multi-society letter is available HERE.
For many years, the Spine Intervention Society has had an actively participating representative and professional staff at all RUC and CPT meetings. The Society is the only interventional pain organization with consistent participation and volunteers and staff at each meeting.
The Resource-Based Relative Value Scale (RBRVS) Update Committee (RUC) is an advisory body to the Centers for Medicare and Medicaid Services charged with recommending relative value units (RVUs) that determine the reimbursement level for each CPT code. The RUC assesses the resource costs needed to provide specific services, broken down by physician work, practice expense, and professional liability insurance. Payments are calculated using a conversion factor, determined by CMS.
More information can be obtained at http://www.ama-assn.org/ama/go/rbrvs
The CPT Editorial Panel is in charge of the development and revisions of Current Procedural Terminology procedure codes. More information can be obtained at http://www.ama-assn.org/ama/pub/physician-resources/solutions-managing-your-practice/coding-billing-insurance/cpt.page
The Spine Intervention Society participates in the following CPT activities:
CPT Spinal Codes Issues Workgroup
Society representative Dr. Scott Horn, who has been actively participating in the CPT process on The Spine Intervention Society's behalf for over five years, has been appointed to the CPT Editorial Panel Spinal Issues Workgroup. This workgroup is composed of key stakeholders who work on assuring consistent description and differentiation of spinal procedures within the CPT code set. The confidential meetings take place by phone and in-person with the goal to develop a proposal that can be presented to the CPT's Editorial Panel.
CPT Literature Review Workgroup
The CPT Editorial Panel created a Workgroup to review current literature requirements for new codes. The Spine Intervention Society staff/representatives are attending the meetings to track progress of this issue and provide input, when necessary.
Perplexed about coding requirements?
Confused about how to code your practice's procedures?
Submit your questions HERE (Members Only).
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