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    Highlights of the 2015 Medicare Physician Fee Schedule Final Rule: Provisions Affecting Invasive/Interventional Cardiology

    November 07, 2014

    The Centers for Medicare and Medicaid Services (CMS) released the 2015 Medicare Physician Fee Schedule (MPFS) Final Rule on October 31, 2014. The Final Rule includes the interim values assigned by CMS for all new codes that go into effect on Jan. 1, 2015. The Rule, issued on Halloween, was not without its tricks and treats.

    Conversion Factor Frozen Through March 31, 2015

    With legislation already in place that freezes the Medicare conversion factor through March 31, 2015, the annual “SGR fix” cliff-hanger has been delayed for a few extra months this year. SCAI anticipates that we will again seek member support to rally for an SGR fix in the first quarter of 2015. The House of Cardiology will again need to work together to achieve legislation that averts the anticipated, across-the-board 21.2 percent fee cut slated for April 1, 2015.

    CMS Accepts SCAI- and RUC-Recommended Values for New TMVR Codes

    The new transcatheter mitral valve repair (TMVR) codes reflect the valuation recommendations of SCAI and the RUC. Clifford J. Kavinsky, MD, PhD, FSCAI, whorepresents SCAI to the RUC, was instrumental in securing the values received for the new TMVR codes. The code for the initial clip placement (33418) was assigned a Medicare reimbursement rate of $1,923. The code that will be used to report second and subsequent clips placed (33419) received a value of $451. To put the values of the new TMVR codes in perspective, the percutaneous femoral TAVR code (33361) has a payment rate of $1,396.  However, the TAVR code requires co-surgeon status for its performance translating to each operating receiving payment $872.

    All 10- and 90-day Global Period Valuations to Be Eliminated

    CMS has elected to move forward with the elimination of 10- and 90-day global periods. These codes will be converted to 0-day codes by Jan.1, 2018. Interventional Cardiology has a small number of procedures with 90-day global periods that will be impacted:  percutaneous valvuloplasty, AAA and TAA endovascular repair, carotid stenting, and now the new initial placement TMVR code. In comments submitted last August in response to this proposal, SCAI softly supported CMS’s proposed elimination of 10-day and 90-day global periods.SCAI stressed that, “If properly executed, [we] strongly believe that greater accuracy in the valuation of services could possibly be achieved through the elimination of these global periods.” While SCAI anticipates the values for the inherent follow-up E&M services built into the valuations of these 90-day codes will be cleaved-out, follow-up E&M will become separately reportable, which, if the current values are accurate, should result in no change in overall valuation for the physician work provided.

    CMS Moves Forward with Enhanced Transparency in Rate-setting

    The Final Rule also delivered notice of CMS’s commitment to a new schedule for the valuation of new/revised codes. Under the new model providers will no longer have to wait for the Final Rule each year in order to learn what CMS decided about valuations for new and revised codes. Instead, going forward, CMS staff is now reporting that if they receive RUC recommended values by Feb. 15 of the preceding year, CMS will present its proposed values for these new/revised codes in the proposed rule, which is typically issued in early July of each year.

    We anticipate the new Category 1 code that SCAI currently has in the pipeline for Transcatheter Pulmonary Valve Implantation (TPVI) will meet the required proposed valuation submission deadline and will be the first interventional cardiology code to benefit from this new transparency in rate setting.

    CMS Accepts SCAI Recommendations for Surgical Malpractice Factor Assignment

    CMS also agreed with SCAI’s recommendation that the malpractice risk associated with the cardiac catheterization and angioplasty services are “more akin to surgical procedures than most non-surgical services.” As a result, cardiac catheterization and angioplasty services as described by HCPCS codes 92961, 92986, 92987, 92990, 92997, and 92998 will be added to the list of services outside of the surgical HCPCS code range to be considered surgery for purposes of assigning service-level malpractice risk factors.

    CMS Will Track Claims from Off-Campus Provider-Based Departments

    With a growing number of physicians moving from private practice to hospital employment, CMS has high interest in tracking claims for off-campus provider-based departments. To support the tracking of these claims, CMS will issue a new POS (place of service) code for provider use. The code is expected to be issued by July 1, 2015. Hospitals will need to add a modifier to their billings to support tracking their claims for the technical component for these services. SCAI will be monitoring these developments closely so we can provide accurate and timely guidance to our members to ensure proper reporting and coding of these services.