The Centers for Medicare and Medicaid Services (CMS) recently released proposed changes to the Medicare allowances for physicians’ services paid under the Physician Fee Schedule (PFS) and services provided by hospital outpatient departments paid under the Hospital Outpatient Prospective Payment System (HOPPS). If the changes are adopted as proposed, the amounts paid for physicians services (Professional and Technical Components) under the PFS would remain relatively unchanged in 2016, but hospitals would experience significant changes in the amounts paid by Medicare for the overhead, supplies, equipment, and non-physician personnel costs associated with outpatient echos. Read more here.
Modest Changes in Echo Professional Fees But Significant Changes in Hospital Outpatient Echo Payment Proposed by Medicare for 2016 (7/10/15)
The American Medical Association and CMS jointly announced that an agreement has been reached on important elements of a “grace period” for the October 1, 2015, implementation of the ICD-10 diagnosis code set.
In guidance that is being transmitted, CMS announced that:
- For a one year period starting October 1, Medicare claims will not be denied solely on the specificity of the ICD-10 diagnosis codes provided, as long as the physician submitted an ICD-10 code from an appropriate family of codes. In addition, Medicare claims will not be audited based on the specificity of the diagnosis codes as long as they are from the appropriate family of codes. This policy will be followed by Medicare Administrative Contractors and Recovery Audit Contractors.
- To avoid potential problems with mid-year coding changes in CMS quality programs (PQRS, VBM and MU) for the 2015 reporting year, physicians using the appropriate family of diagnosis codes will not be penalized if CMS experiences difficulties in accurately calculating quality scores (i.e., for PQRS, VBM, or Meaningful Use). CMS will continue to monitor implementation and adjust the duration if needed.
- CMS will establish an ICD-10 Ombudsman to help receive and triage physician and provider problems that need to be resolved during the transition.
- CMS will authorize advanced payments if Medicare contractors are unable to process claims within established time limits due to problems with ICD-10 implementation.
The October 1 deadline for implementation of the ICD-10 code set is fast approaching, and time is running out for physician practices to complete their preparation. The AMA has a broad range of materials available on its web site to help physicians prepare for the October 1 deadline. For additional information please visit here.
The Centers for Medicare and Medicaid Services (CMS) released the proposed rule to the Hospital Outpatient Prospective and Ambulatory Surgical Center Payment Systems.The proposed rule also includes important proposed changes to the Two Midnight Rule for CY 2016. See this related fact sheet for detailed information on this rule and click here to view the full detailed fact sheet on CMS changes. ASE is analyzing these recommendations and will share a more detailed and targeted analysis soon.
On July 1, 2015 the American Medical Association (AMA) released its semi-annual update to its list of CPT Category III codes. The AMA identified 34 new Category III codes; these codes all are scheduled to become effective as of January 1, 2016. Of particular interest to Echocardiographers is 0399T – Myocardial strain imaging as described below:
- 0399T: Myocardial strain imaging (quantitative assessment of myocardial mechanics using image-based analysis of local myocardial dynamics)
►(Use 0399T in conjunction with 93303, 93304, 93306, 93307, 93308, 93312, 93314, 93315, 93317, 93350, 93351, 93355)◄
►(Report 0399T once per session)◄
Reminders for your practice
- Typically Category III codes replace unlisted codes that were previously used for new procedures or services. Prepare to update your charge sheets.
- If a Category III code describes the procedure or service performed, it must be reported. An unlisted code or less specific Category I cannot be reported in place of an active Category III code.
- Reimbursement of Category III codes is at the discretion of payers. During the six months between announcement of new Category III code and active date, practices interested in utilizing new code should begin working with local payers to obtain coverage and payment.
- Category III codes are released on a semi-annual basis in January and July and are published on the AMA’s website. Please reference the AMA website for a complete listing of all recently approved Category III codes
Also, with the passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACA) Congress permanently repealed and replaced the Sustainable Growth Rate Formula and a providing to increase the Medicare conversation faction by .05%. This increase will go into effect today, July 1.
This week, US CMS has published the third annual release of the Medicare hospital utilization and payment data (both inpatient and outpatient) and the second annual release of the physician and other supplier utilization and payment data. As they did last year, state and national media outlets are expected to publish names and details of top billers in forthcoming coverage of this year’s data.
CMS files can be searched by specialty or by state which allows you to compare yourselves to your peers. For more information please visit here.
As always, ASE will monitor press coverage of this data release in the coming weeks, and will continue to alert our members if any articles emerge that are particularly concerning for echocardiography.
Through its contractor, eGlobalTech, CMS has begun issuing national provider Comparative Billing Reports (CBRs) on Transthoracic Echocardiography (TTE). These reports are being sent to approximately 2,500 cardiologists and internists “who were identified as having different billing patterns when compared to their peers.” The reports contain data-driven tables and graphs with an explanation of findings that compare providers’ billing and payment patterns to those of their peers in their state and across the nation. You can view a sample report here.
The stated goal of these reports is to be educational— to inform the providers who receive them about correct Medicare billing practices. Based on this information, ASE is currently monitoring the effect of these notices. Based on our conversations with other medical organizations who have experienced similar CBR reports, it is our understanding that these reports are not related to any audit program. ASE’s advocacy team is in the process of contacting eGlobalTech/Palmetto GBA regarding recent changes in echo utilization and to inquire into the methodology used to identify aberrant billing practices.
Those ASE members who receive a report may wish to find out more by reviewing the FAQs and other information posted by eGlobalTech at http://www.cbrinfo.net/cbr201505.html. For those who want more information, a provider webinar is scheduled for May 27 at 3 p.m. ET. Register online here.
Healthcare providers can breathe a sigh of relief as the Senate passed the H.R. 2 bill late last Tuesday night before the Centers for Medicare and Medicaid Services planned to reduce physician reimbursement by 21.2 percent, as mandated by SGR. President Obama has said he will sign the bill. However, due to timing, it is expected that a “small volume of claims” will be subject to the April 1 cuts. CMS has said that those claims will be reprocessed automatically so that the providers will be made whole and further cuts will be averted.
Your ASE volunteer Advocacy Committee, chaired by David Wiener, MD, FASE, along with ASE’s VP of Health Policy, Irene Butler, our legislative advisor Diane Millman, and lobbyist Peggy Tighe worked tirelessly behind the scenes to bring this bill to Congress without the inclusion of site neutrality language. This was ASE’s key issue this year– to assure protection of our patients ability to access quality cardiovascular care, especially in rural areas often served by one hospital. Your grassroots efforts combined with the ASE advocacy efforts ensured that patient access to echocardiography was preserved in this bill.
You can be confident that ASE continues to work on your behalf with a strong and well organized coalition on this and other issues, such as the opposing the elimination of the in-office ancillary exception. ASE is the leading voice on the Hill for echo-related issues and your membership is key to making this monitoring and activity happen.
While the U.S. Congress and CMS continues to cut many areas of healthcare, ASE is proud to announce that our CPT team succeeded in the acceptance of a new myocardial strain imaging code. ASE was able to present compelling data to establish a Category III code, 039X9T, for imaging of myocardial strain for the detection of myocardial deformation. While Category III codes generally are not reimbursed, they often lead to the adoption of payable codes. This victory is a one step closer to ensuring patients have access to critical care and that our members are appropriately compensated for their important work. We will follow this code closely as it makes its way to CMS and commercial payers.
Please note this code is expected to go into effect on January 1, 2016.
CMS recently made available a Proposed Rule setting forth a number of changes to the Shared Savings Program (SSP) for Accountable Care Organizations (ACOs). ASE has developed a summary of the major changes in the Proposed Rule and addressed some interesting information about ACO performance thus far.