Are you Ready for All the Changes in 2017?

January 31, 2017
by: Michael Main, MD, FASE

The New Year brought new billing and reporting requirements for accurate documentation and coding. ASE is committed to ensuring you are aware of these latest changes to help you comply with the new criteria and receive proper reimbursement for quality care.

CMS’ final Medicare Physician Fee Schedule established a new, across-the-board policy requiring moderate sedation be billed separately from the underlying base codes. This is not an echo-specific change, but does establish a new billing process that could impact your practice. As of January 1, 2017 if you provide moderate (conscious) sedation in conjunction with TEE you must now bill it separately. Payment for moderate sedation is no longer included in the allowances for any TEE codes. If these services are not billed separately they will not be reimbursed. Please use this document to help you bill these services appropriately and ensure correct reimbursement.

The final Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rule was an 800+ page document outlining a complex new healthcare payment system. It is expected that over 90 percent of all physicians will need to comply with the Merit-Based Incentive Payment System (MIPS) to avoid facing penalties. Please visit ASE’s Coding and Reimbursement web-page or MACRA webpage to help you understand how to comply with this new reporting track. Of particular interest to you may be Dr. Geoffrey Rose’s webinar, ASE’s MACRA/MIPS 101: Essentials You Need to Know Webinar. It provides the details of this complex program and outlines practical steps for you to achieve MACRA readiness.

In the final weeks of 2016 CMS released their final rule related to Episode Payment Models (EPMs), which includes mandatory cardiac bundling initiatives. The Trump administration has issued a temporary freeze on all recently published regulations, including the AMI and CABG EPMs. The original implementation date had been February 18, 2017; now the earliest the regulations could become effective is on March 21, 2017. However, commercial carriers may be moving forward with similar EPMs so we encourage you to monitor ASE and commercial carriers’ communications for further information. For a list of metropolitan areas selected for this demonstration and a brief write-up on how this may impact echo please click here. There you will also find a link to an article that may be of interest to you, (“Medicare Sticks with Mandatory Bundled-pay demo, but Tom Price Likely to Intervene.

ASE is actively working to achieve coverage and reimbursement for the echocardiography add-on CPT™ code 0399T (myocardial strain imaging).  This week we learned that AmeriHealth Caritas Pennsylvania considers

“the use of echocardiographic assessment of myocardial strain to measure cardiac impairment in cancer patients treated with chemotherapy to be clinically proven and, therefore, medically necessary”.

CPT 0399T is a “category III” code; these temporary codes are issued for emerging technology, services, and procedures, and allow for utilization tracking (and may in some cases be reimbursed by private payers and Medicare Administrative Contractors).  If substantial utilization and clinical efficacy is demonstrated, category III codes may ultimately be reassigned category I status (with subsequent valuation by the American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC), and national reimbursement by the Centers for Medicare And Medicaid Services (CMS)).

We encourage all echo lab staff and associated business departments to become familiar with this new CPT™ add-on code, and submit it code when performing myocardial strain imaging. This will allow national utilization tracking, a critical first step towards establishing CMS reimbursement for these services.

For more detailed inquiries ASE retains a coding expert to answer your individual coding questions.  The coding and reimbursement web page can be found here: https://www.asecho.org/advocacy/coding-and-reimbursement/, and simply click on “Ask the Coding Expert.”