• Frequently Asked Questions About the CMS Interventional Cardiology Designation

    Do you have questions about the new CMS designation for interventional cardiologists? Does your billing staff need help with the process of changing your designation? SCAI’s Advocacy team developed the Q&A below based on questions submitted by SCAI members and their billing staff. Have a question that’s not addressed below? No problem. Contact SCAI’s Director of Reimbursement & Regulatory Affairs, Dawn R. Gray, at dgray@SCAI.org.

     

    Why should I change my designation with the Centers for Medicare & Medicaid Services (CMS)? Does it matter if CMS considers me a cardiologist rather than an interventional cardiologist?

    How will the CMS designation result in fewer claims denials?

    How will the CMS designation lead to fairer evaluation of resource utilization?

    How will the CMS designation lead to improved evaluation of performance and outcomes?

    How will CMS’s new designation support better data and enhanced advocacy?

    Can we use the online PECOS option to update a physician’s specialty type to Interventional Cardiology?

    Can physicians still select Cardiology as their secondary specialty?

    Must I be Board certified in interventional cardiology to take advantage of CMS’s new designation?

    Will CMS make the specialty designation retroactive for billing purposes?

    Most physicians who perform percutaneous coronary interventions also provide other services, such as staffing clinics. Some even support their hospital’s electrophysiology team. If this describes my practice, will I need two billing numbers?

    If I change my designation to interventional cardiologist, will I need to change my practice patterns and provide a consultative E&M service before all of my diagnostic cardiac catheterization and PCI procedures? 

    How does the Interventional Cardiology designation apply if I practice in an accountable care organization (ACO)?

    How do I change my designation? Is it complicated?

    What if I have more questions, or my coding staff need help?

    Is there any downside to changing my designation?

    Can I change it back if I find it is not working for me?

     

    Q:        Why should I change my designation with the Centers for Medicare & Medicaid Services (CMS)? Does it matter if CMS considers me a cardiologist rather than an interventional cardiologist?

    A:         Being identified as an interventional cardiologist by CMS is one of the most important professional opportunities available to you today. Once your designation is updated in the CMS database, you should experience –

    • Fewer claims denials
    • Fairer evaluation of your resource utilization
    • Improved evaluation of your outcomes and performance
    • Better data and enhanced advocacy

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    Q:        How will the CMS designation result in fewer claims denials?

    A:         Under your current designation as a general cardiologist, if you and another cardiologist in your group both participate in a patient’s care generally only one of you can be reimbursed for any E&M (Evaluation and Management) work you do.   Once designated as an interventional cardiologist, you both can be fairly reimbursed for your own distinct work without concerns about duplicate claims. This is because the work of each of you does will now be recognized for its unique value to the patient.

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    Q:        How will the CMS designation lead to fairer evaluation of resource utilization?

    A:         The separate designation code for interventional cardiology should reduce or even eliminate unfair apples-to-oranges comparisons among cardiologists who provide distinct services to patients. Before the addition of the new specialty code, interventional cardiologists were grouped with general cardiologists, internists and other less-intensive physicians in payers’ administrative databases.  The interventionalists’ resource utilization naturally skewed toward the high end of the curve without any context about why greater resource utilization should be expected by the physicians who deliver interventions. Using the interventional cardiology designation will help ensure that these scores are peer-to-peer comparisons with other interventionalists.

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    Q:        How will the CMS designation lead to improved evaluation of performance and outcomes?

    A:         In the absence of an interventional cardiology designation, the outcomes of interventional cardiologists' patients have been compared with the outcomes of patients of non-invasive cardiologists or internists. There has been no mechanism for recognizing that interventionalists’ patients were often sicker, requiring more complex treatment and accompanying longer stays in the hospital. In these scenarios, quality-of-care performance scores for interventional cardiologists may have been negatively impacted.  These scores are often used by patients in choosing a physician, by trial attorneys in litigation, by hospital administrators as well as by journalists covering health care. By eliminating these apples-to-oranges comparisons, the new interventional cardiology designation levels the playing field.  This has the potential to enhance your stature in contract negotiations and, most importantly, can allow you to truly compare yourself to your peers to enhance the care you provide your patients.  It also has the potential to improve public perception of the specialty.

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    Q:        How will CMS’s new designation support better data and enhanced advocacy?

    SCAI filed for a dedicated physician specialty code in 2013, upon confirming with government officials and other analysts that Interventional Cardiology has evolved to a point where many of the patients whom interventional cardiologists treat and the treatments they can offer are significantly different from those of general cardiology and other cardiovascular subspecialties. Having a designated specialty will help ensure that your concerns and priorities receive sufficient consideration and are not lumped in with those of non-interventionalists. This is especially important in today’s healthcare environment when CMS and other payers are profiling providers based on the costs of the services they deliver to beneficiaries. SCAI expects that payers will soon be calculating the costs of procedures performed by interventional cardiologists and comparing those costs to those for treatments provided by noninvasive cardiologists, potentially leading to unfair comparisons of practice patterns and erroneous reporting of our members as outliers.

    Also, Medicare beneficiaries who turn to CMS’s Physician Compare website should soon be able to quickly and uniquely identify you as an interventional cardiologist who is providing services in their area. This is because the new designation, “Interventional Cardiology,” will be added as a unique specialty on the Physician Compare website. Currently, when a patient searches for the keyword “stent,” Physician Compare generates a list of specialists in Cardiac Surgery, Cardiovascular Disease (Cardiology), Diagnostic Radiology, Interventional Radiology, Neurosurgery, Peripheral Vascular Disease, Thoracic Surgery and Vascular Surgery.”

    Finally, the new interventional cardiology designation will also allow for more accurate data on the total number of interventional cardiologists and interventional procedures in the United States as well as more accurate aggregated performance scores. This more reliable information will help SCAI to clarify its advocacy platform with policymakers on both state and national levels, yielding a better regulatory environment for the field. 

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    Q:        Can we use the online PECOS option to update a physician’s specialty type to Interventional Cardiology?

    A:         Not yet. According to communications from CMS staff, the PECOS online option will not be available until July 2015 at the earliest. CMS is advising providers to submit form cms855i form. This form is available for download on the CMS website or just search CMS 855i.  On page 7 of this form, you should identify the provider’s Primary Specialty as “P-Interventional Cardiology” in the open “other” field on the form (it’s on the bottom right). This form may be filled out by your office staff.

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    Q:        Can physicians still select Cardiology as their secondary specialty?

    A:         Yes. The provider may elect to select a secondary specialty. The secondary specialty would be marked with an “S” on the form to indicate it is “secondary.” For example, an interventional cardiologist might designate “P-Interventional Cardiology” and “S-Cardiology” for, respectively, his or her primary and secondary specialties.

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    Q:        Must I be Board certified in interventional cardiology to take advantage of CMS’s new designation?

    A:         SCAI’s understanding is that your primary and secondary CMS designations are your choice. They do not require Board certification. Keep in mind that CMS uses designation information to track and analyze resource utilization. Your specialty designation should reflect your clinical practice. If you spend a large portion of your clinical time evaluating the appropriateness of invasive procedures and interventions, performing interventions, and providing follow-up care, rather than in non-invasive cardiology care, then you should benefit by being correctly classified as an interventional cardiologist.

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    Q:        Will CMS make the specialty designation retroactive for billing purposes?

     

    A:         The specialty designation went into effect on January 1, 2015, with an implementation date of January 5, 2015, according to MedLearn. It is likely that carriers will use the date that the necessary paperwork (cms855i form) was submitted or approved as the effective date for claims processing. This is why we are urging all interventional cardiologists to submit their completed forms as quickly as possible. You should also track your submission and approval dates closely. Your local carrier should be able to provide definitive guidance about the date that will be used for claims processing.

    SCAI expects that CMS will use January 1, 2015, as the start date for tracking providers’ resource utilization and reporting. Being correctly identified as an interventional cardiologist in CMS’s databases will benefit you and your profession. This designation will generate more accurate data on the total number of interventional cardiologists practicing and the volume of interventional procedures performed in the United States as well as more accurate aggregated performance scores. This more reliable information will ensure your resource consumption is fairly evaluated and help SCAI to clarify its advocacy platform with policymakers, yielding a better regulatory environment for the field. 

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    Q:        Most physicians who perform percutaneous coronary interventions also provide other services, such as staffing clinics. Some even support their hospital’s electrophysiology team. If this describes my practice, will I need two billing numbers?

    A:         No, you will not need two billing numbers, no matter what your specialty designation.

    Your specialty designation identifies you as an interventional cardiologist. The designation does not limit your ability to provide (or bill for) E&M services in addition to performing procedures. Specifying your primary specialty as interventional cardiology may even ENHANCE your ability to report and be paid for E&M services. Here’s why:  In the past, when two physicians in the same practice with the same designation saw the same patient on the same day, CMS almost always denied the second claim because it was viewed as a duplicate service. Now, if you are designated as an interventional cardiologist, you can expect to be reimbursed when you provide a “consult” as long as that patient was not seen by another CMS-designated interventional cardiologist in your practice that same day. Additionally, often you will be able to classify that patient as a “new patient,” which supports a higher reimbursement rate than an “established patient” does. Of course, you must adhere to all Medicare rules and regulations regarding E&M coding (for more information, click here), but being designated as an interventional cardiologist should support greater accuracy because you will be able to more accurately report your services.  

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    Q:        If I change my designation to interventional cardiologist, will I need to change my practice patterns and provide a consultative E&M service before all of my diagnostic cardiac catheterization and PCI procedures? 

    A:         You DO NOT have to change your practice pattern at all. The following policies apply regardless of your specialty:

    • 0-day global period codes, such as diagnostic cardiac cath and PCI codes, include pre-service evaluation related to the procedure. That work is not separately reportable as an E&M visit.
    • Same-day E&M visits are reportable when the visit includes decision-making at which the “decision to proceed” with an intervention is made.

    Your specialty designation should reflect your current practice style. If you spend a large portion of your clinical time evaluating patients for invasive/interventional procedures, performing those procedures and providing post-procedure care for those patients, versus providing general cardiology E&M services, then you are an interventional cardiologist. Being formally designated as an interventional cardiologist in the Medicare system should be beneficial to you and your practice.

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    Q:        How does the Interventional Cardiology designation apply if I practice in an accountable care organization (ACO)?

    A:         SCAI sought the guidance of Harold Miller, a leading expert on ACOs, to determine whether we should seek an exemption for interventional cardiology in ACO attribution calculations. Professor Miller concurred that providers who spend the preponderance of their clinical time performing interventions should seek exemption from ACO attribution calculations.

    SCAI has asked CMS to exempt Interventional Cardiology from ACO attribution calculations. CMS has already proposed exempting electrophysiology, interventional radiology, vascular surgery and thoracic surgery in the ACO’s Proposed Rule issued last December.

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    Q:        How do I change my designation? Is it complicated?

    It’s not complicated to change your specialty designation with CMS. It requires completing some paperwork that your billing staff should be familiar with. Please ask your billing staff to complete the following steps:

    1. Go to http://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/cms855i.pdf, and download Form cms855i for “Changing Your Medicare information.”
    2. Complete this form. The key field is on page 7. In response to “d.1 Physician Specialty,” be sure to check “Undefined physician type (specify)” and then enter “P-interventional cardiology.”  
    3. Submit a hard copy of the completed form to the local Medicare Administrative Contractor.
    4. When this form is submitted, please notify SCAI’s Director of Reimbursement & Regulatory Affairs, Dawn R. Gray, at dgray@SCAI.org. Provide the physician’s name, contact information, and Medicare number. SCAI will be tracking enrollment numbers to ensure that national and local records match. 
    5. File a copy of the completed form for your records.

    Keep in mind that CMS’s specialty designation process will continue to evolve as CMS implements online options. SCAI will keep you informed of changes to this process.

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    Q:        What if I have more questions, or my coding staff need help?

    That’s what we’re here for. We invite you and your billing staff to contact SCAI’s Director of Reimbursement & Regulatory Affairs, Dawn R. Gray, at dgray@SCAI.org.

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    Q:        Is there any downside to changing my designation?

    We have not been able to identify any potential downside to having interventional cardiologists identify themselves as interventional cardiologists.  

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    Q:        Can I change it back if I find it is not working for me?

    If for some reason switching your personal Medicare profile specialty type to “Interventional Cardiology” doesn’t work out for you, you can always switch it back. Changing your specialty back can be accomplished using an online PECOS form. We are quite certain that once you’ve been identified as an interventional cardiologist, you won’t want to go back!