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2019 Physician Fee Schedule Final Rule: CMS to Share Info.

The Centers for Medicare & Medicaid Services (CMS) will hold a Medicare Learning Network (MLN) call on Monday, November 19 from 2:00 to 3:30 P.M. ET to discuss Key Topics related to the 2019 Physician Fee Schedule Final Rule. According to MLN, “CMS experts briefly cover three provisions and address your questions: Streamlining Evaluation and […]

The post 2019 Physician Fee Schedule Final Rule: CMS to Share Info. appeared first on AAPC Knowledge Center.

AAPC Knowledge Center

CPT 00670 remove from IPO list Nov 2nd Final Rule

Below is my formal comment to CMS regarding the removal of CPT 00670 from the inpatient only list for 2019 OPPS/ASC Final Rule. We had received a denial in the past for ACDF procedure with instrumentation where it was performed on observation basis since this typically an overnight procedure and does not qualify for the two midnight rule and CPT 22845 had been removed from the IPO list with the last couple of years. The insurance carrier used Medicare’s inpatient only list which is for hospital to state the professional claim could not be billed with place of service 22 for CPT 00670 because it was an inpatient only procedure according to CMS. So I requested them to remove it from the IPO list and now the final rule has come out, they have accepted the request.

July 26,2018
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Comment Tracking Number: 1k2-94hv-zwdm
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Agency: Centers for Medicare Medicaid Services (CMS)
Document Type: Rulemaking
Title: Hospital Outpatient PPS Policy Changes and Payment Rates and Ambulatory Surgical Center Payment System Policy Changes and Payment Rates CMS-1695-P
Document ID: CMS-2018-0078-0001
Comment:
In regards to the Inpatient only list, I believe CPT 00670 should be removed from the inpatient only list. There were many spinal instrumentation codes previously removed from the inpatient list that CPT 00670 corresponded too. Now that the majority of spinal instrumentation codes have been removed from the inpatient only, it seems that the corresponding anesthesia code to bill in conjunction with these services should also be removed.

________________________________________________

https://s3.amazonaws.com/public-insp…2018-24243.pdf

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
42 CFR Parts 416 and 419
[CMS-1695-FC]
RIN 0938-AT30
Medicare Program: Changes to Hospital Outpatient Prospective Payment and
Ambulatory Surgical Center Payment Systems and Quality Reporting Programs
AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS

__________________________________________________ _
Comment: Several commenters recommended the removal of several procedures not originally proposed by CMS for removal from the IPO list for CY 2019. These
recommended procedures related to other procedures that were recently removed from the IPO. In addition, several commenters recommended the removal of all orthopaedic,
arthroplasty, and joint replacement procedures from the IPO list. T

Table 48 below contains the procedures that were explicitly requested by the commenters to be removed
from the IPO list for CY 2019.

TABLE 48.—PROCEDURES REQUESTED BY COMMENTERS TO BE REMOVED FROM THE INPATIENT ONLY LIST FOR CY 2019
CPT Code Descriptors

00670 Anesthesia for extensive spine and spinal cord procedures (eg, spinal instrumentation or vascular procedures)
63265 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; cervical
63266 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; thoracic
63267 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; lumbar
63268 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; sacral

Response: We appreciate the diligence that commenters continue to show in proposing changes to the IPO list. For the CY 2019 OPPS, we believe that it is appropriate to remove the procedure described by CPT code 00670 from the IPO list, as
recommended by the commenters. We refer readers to the CY 2017 OPPS/ASC final rule with comment period (81 FR 79695 through 79696) in which CMS removed six
related codes (four spine procedure codes and two laryngoplasty codes) from the IPO list for CY 2017. We believe that the procedure described by CPT code 00670 is appropriate
for removal from the IPO list because it relates to the following codes that CMS removed from the IPO list in CY 2017: CPT code 22840 (Posterior non-segmental
instrumentation (eg, Harrington rod technique, pedicle fixation across 1 interspace, atlantoaxial transarticular screw fixation, sublaminar wiring at C1, facet screw fixation)
(List separately in addition to code for primary procedure)); CPT code 22842 (Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and
sublaminar wires); 3 to 6 vertebral segments (List separately in addition to code for primary procedure)); CPT code 22845 (Anterior instrumentation; 2 to 3 vertebral
segments (List separately in addition to code for primary procedure)); and CPT code 22858 (Total disc arthroplasty (artificial disc), anterior approach, including discectomy
with end plate preparation (includes osteophytectomy for nerve root or spinal cord decompression and microdissection); second level, cervical (List separately in addition to
code for primary procedure)). We also believe that this procedure is being performed in numerous hospitals on an outpatient basis. Accordingly, we are removing the procedure
described by CPT code 00670 from the IPO list for CY 2019. Because this spine procedure code is an add-on code, in accordance with the regulations at
42 CFR 419.2(b)(18), under the OPPS, this procedure is packaged with the associated procedure and assigned status indicator “N” (Items and Services Packaged into APC
Rates) for CY 2019.
With respect to the commenters’ recommendation that we remove CPT code 63265 (Laminectomy for excision or evacuation of intraspinal lesion other than
neoplasm, extradural; cervical), CPT code 63266 (Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; thoracic), CPT code
63267 (Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; lumbar), and CPT code 63268 (Laminectomy for excision or
evacuation of intraspinal lesion other than neoplasm, extradural; sacral) from the IPO list, we intend to continue to review these procedures and the appropriateness of the potential
removal from the IPO list for subsequent rulemaking. In regard to the commenters’ recommendation to remove all orthropaedic, arthroplasty, and joint replacement procedures from the IPO list, we do not believe that
we have sufficient data to support removal of all orthopaedic, arthroplasty, and joint replacement procedures from the IPO list. However, we encourage stakeholders to
submit specific procedures, along with evidence, to support their requests for removal from the IPO list. In conclusion, the complete list of procedure codes that are placed on the IPO list
for CY 2019 is included as Addendum E to this CY 2019 OPPS/ASC final rule with comment period (which is available via the Internet on the CMS website).

Table 49 below contains the final changes that we are making to the IPO list for CY 2019.
TABLE 49.—CHANGES TO THE INPATIENT ONLY LIST FOR CY 2019
CY 2019 CPT Code CY 2019 Long Descriptor Action CY 2019 OPPS APC Assignment CY 2019 OPPS Status Indicator

31241 Nasal/sinus endoscopy, surgical; with ligation of sphenopalatine artery Removed from IPO list

01402 Anesthesia for open or surgical arthroscopic procedures on knee joint; total knee arthroplasty

0266T Implantation or replacement of carotid sinus baroreflex activation device; total system (includes generator placement, unilateral or bilateral lead placement,
intra-operative interrogation, programming, and repositioning, when performed).

00670 Anesthesia for extensive spine and spinal cord procedures (eg, spinal instrumentation or vascular procedures) Removed

C9606 Percutaneous transluminal revascularization of acute total/subtotal occlusion during acute myocardial infarction, coronary artery or coronary
artery bypass graft, any combination of drug-eluting intracoronary stent, atherectomy and angioplasty, including aspiration thrombectomy when
performed, single vessel

Medical Billing and Coding Forum

Final post op visit with complications

Can I please have your opinion…….

Patient underwent surgery and has now presented to the office for his final post operative visit. He has now developed cellulitis around his incision and the need for hospital admission for IV antibiotics, etc.

Since the patient in still within his global period and this appears to be a related complication of his surgery, is then anything other than a post operative visit you can bill?

Thank you!

Medical Billing and Coding Forum

2016 OPPS final rule introduces new modifiers and restructured APCs

Providers need to be aware of new modifiers added by CMS in the 2016 OPPS final rule, including a data collection and payment modifier that go into effect January 1, 2016.

Data collection modifier limited to one C-APC
Providers will only have to report a new data collection modifier when reporting related/adjunctive services associated with one comprehensive APC (C-APC), the stereotactic radiosurgery (SRS) C-APC, rather than all C-APCs, which is what CMS originally proposed. 
 
Because so many commenters expressed concerns and raised many operational and technical questions to CMS about using the new modifier to report related/adjunctive services for all C-APCs, CMS backed off its original proposal, says Jugna Shah, MPH, president and founder of Nimitt Consulting, based in Washington, D.C., and Spicer, Minnesota.
 
“This is really great news for two reasons,” says Shah. “First, it shows that CMS listens when providers speak, and particularly when they raise good operational points. Second, it will be easier for providers to operationalize the use of this modifier for the SRS C-APC, only rather than for all C-APCs.”
 
CMS will require modifier –CP (adjunctive service related to a procedure assigned to a C-APC procedure, but reported on a different claim) for adjunctive services related to SRS services described by the following codes but reported on a separate claim:
  • 77371, radiation treatment delivery, SRS, complete course of treatment cranial lesion(s) consisting of one session; multi-source Cobalt 60-based
  • 77372, radiation treatment delivery, SRS, complete course of treatment cranial lesion(s) consisting of one session; linear accelerator based
CMS expects the new modifier to be used with adjunctive services provided within 30 days prior to SRS treatment.
 
“It may be easier for providers to bill claims for these services for the entire month rather than trying to keep track of applying modifier –CP,” says Rinkle.
 
CMS explains what it means by related or adjunctive in the final rule by stating:
…services that are integral, ancillary, supportive, or dependent that are provided during the delivery of the comprehensive service. This includes the diagnostic procedures, laboratory tests and other diagnostic tests, and treatments that assist in the delivery of the primary procedure; visits and evaluations performed in association with the procedure; uncoded services and supplies used during the service; outpatient department services delivered by therapists as part of the comprehensive service; durable medical equipment as well as prosthetic and orthotic items and supplies when provided as part of the outpatient service; and any other components reported by HCPCS codes that are provided during the comprehensive service, except for mammography services and ambulance services…  
 
Examples of the types of questions commenters raised about reporting the new modifier, include:
  • Should facilities report adjunctive planning and preparation services when furnished in a setting outside of the hospital outpatient department?
  • Are adjunctive services limited to preoperative testing and planning services only?
  • Does the modifier apply to services performed by different physicians within a health system?
 
CMS did not answer these questions in the final rule, but instead indicated that it will address these and other issues in sub-regulatory guidance prior to January 1, 2016. 
 
The agency also noted in the final rule that it may consider its proposal to expand the use of this modifier to all C-APCs in the future.
 
CMS adds modifier –CT
As a result of the Protecting Access to Medicare Act of 2014, CMS is introducing modifier –CT (computed tomography services furnished using equipment that does not meet each of the attributes of the National Electrical Manufacturers Association [NEMA] XR-29-2013 standard) effective January 1, 2016.
 
Providers will need to append this modifier to a predetermined list of CPT®/HCPCS codes for CT scans when the services are furnished on equipment that does not adhere to NEMA standard XR-29-2013.
 
Those codes are:
  • 70450–70498
  • 71250–71275
  • 72125–72133
  • 72191–72194
  • 73200–73206
  • 73700–73706
  • 74150–74178
  • 74261–74263
  • 75571–75574
 
When these codes are reported with the modifier on a claim to be paid separately (i.e., not packaged into a composite APC or C-APC), CMS will impose a 5% payment reduction in 2016 and a 15% payment reduction beginning in 2017. This payment reduction applies under both the Medicare Physician Fee Schedule and the OPPS.
 
For more information on requirements for reporting modifier –CT, see CMS Transmittal 3402.
 
APC restructuring
CMS followed through with its proposal to restructure APCs for nine clinical families, with a few tweaks for specific services and procedures based on commenter suggestions.
 
“This may be the single largest restructuring of APC groups since the inception of OPPS,” says Shah. “And it’s likely just the beginning.”
 
CMS based the new groupings on the following:
  • Greater simplicity and improved understandability of the OPPS APC structure
  • Improved clinical homogeneity
  • Improved resource homogeneity
  • Reduced resource overlap in longstanding APCs
 
Following restructuring of ophthalmology and gynecology APCs in the 2015 OPPS final rule, CMS finalized restructuring in the following clinical families in the 2016 final rule:
  • Airway endoscopy procedures
  • Cardiovascular procedures and services
  • Diagnostic tests and related services
  • Eye surgery and other eye-related procedures
  • Gastrointestinal procedures
  • Gynecologic procedures and services
  • Incision and drainage and excision/biopsy procedures
  • Imaging-related procedures
  • Orthopedic procedures
 
For full details of changes to APCs relevant for your facility, see section III.D of the final rule.
 
Editor’s note: The 2016 OPPS final rule was published in the November 13 issue of the Federal Register. This article was originally published in Briefings on APCs. Email your questions to editor Steven Andrews at [email protected].
 
 

HCPro.com – JustCoding News: Outpatient

ONC releases final 2016 interoperability standards

The ONC published the final 2016 Interoperability Standards Advisory (ISA) December 22, 2015. The final version includes structural changes available in the fall 2015 draft version. Each standard and implementation specification is assigned six informative characteristics that describe its maturity and adoptability. These informative characteristics will also allow the measures and standards to be tracked as they progress through updates and version, and the rate at which they are adopted, ONC said in a blog post.

The 2016 ISA has undergone significant changes from the 2015 version. These changes are largely attributed to the two rounds of public comment periods ONC conducted, as well as recommendations from the HIT Standards Committee, according to ONC. The most notable changes and additions are:

  • The inclusion of “interoperability needs,” or desired outcomes for each standard
  • Informative characteristics to describe the status and adoption of each standard and implementation specification
  • Subsections that describe attributes or usage concerns such as limitations or general security recommendations
  • Security standards sources appendix
  • “Projected additions” section
  • Summary public comments that were not incorporated into the 2016 ISA including ONC’s responses
  • Revision history section

Other changes from the draft version include revisions and descriptions for the informative characteristics.

The 2016 ISA will serve as the basis for the 2017 version. The comment period to develop the 2017 version will begin early this year.

HCPro.com – HIM-HIPAA Insider