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July 21, 2010 — CMS Announces Final Rules to Support ‘Meaningful Use’ of Electronic Health Records. More information.
Equipment Ownership and Referral Policy
On April 16, 2010, House Energy and Commerce Committee Chairman Henry Waxman, House Ways and Means Committee Chairman Sander Levin, and Representative Pete Stark, Chairman of the Ways and Means Subcommittee on Health, sent a request to the Government Accountability Office (GAO), asking GAO to study and report to Congress on the extent of self referral in advanced imaging and radiation oncology services provided to Medicare beneficiaries, and the costs incurred by Medicare as a result of self referral arrangements. GAO is also directed to study whether self referral may increase the provision of advanced diagnostic imaging and radiation oncology services under Medicare. To view a copy of the Congressional request to GAO, click here.
SCCT is pleased to announce that the Centers for Medicare & Medicaid Services (CMS) released technical corrections to the 2010 Medicare Physician Fee Schedule on May 7, 2010. More Information.
Reimbursement Update United States Senate finally approved legislation to reinstate Medicare physician fees to 2009 levels. More Information.
On March 30 and 31, 2010, SCCT President Jack A. Ziffer, MD, PhD, participated in the Food and Drug Administration's public meeting on ways to reduce radiation exposure from medical imaging. More Information.
March 29, 2010
Holding of April Claims for Services Paid Under the 2010 Medicare Physician Fee Schedule (MPFS)
The Temporary Extension Act of 2010 extended the zero percent (0%) update to the 2010 MPFS through March 31, 2010. Unfortunately Congress left for the Spring District Work Period on March 26th without addressing physician payment for 2010. Therefore a 21 percent Medicare cut to physicians is scheduled to begin on April 1st.
CMS believes that Congress will work to address this when they return to Washington, DC April 9th. Consequently they have instructed contractors to hold claims containing services paid under the MPFS (including anesthesia services) for the first 10 business days of April. This hold will only affect claims with dates of service April 1, 2010, and forward.
SCCT will continue to update our members as additional information becomes available.
Congress Passes Health Care Reform Legislation March 21, 2010
Addendum: The Senate has failed to approve the House provision to halt the 21.2 percent Medicare physician payment cut. This means that effective April 1, 2010, a cut of 21.2 percent will apply to every Medicare service billed. Now, the Senate has gone home for the Spring District Work Period. Be sure to contact your two U.S. Senators and express your outrage that the Senate has yet again failed patients and physicians.
Late March 21, 2010, the U.S. House of Representatives approved the Senate version of health care reform by a vote of 219 212. The President signed the bill into law March 23, 2010. Key provisions of the legislation include health insurance reforms, coverage for the uninsured, and prevention and wellness initiatives. Medicare physician payment reform is not addressed in this legislation.
The House of Representatives also approved, by a vote of 220 - 211, a package of changes to the Senate bill under a process called reconciliation. The Senate must now approve the House changes to the Senate bill. At this point it is uncertain if the Senate will approve the reconciliation package. (remove these last two sentences) and replace them with "The Senate recently approved the reconciliation changes."
Click here to view a summary of key provisions of the health care reform and reconciliation bills.
Reimbursement Alert
Congress passed and President Obama signed into law (December 21, 2009) a provision to delay the scheduled 21.2 percent Medicare physician payment cut until March 1, 2010. The cut was slated to take effect January 1, 2010, due to mandated adjustments in the conversion factor under the Sustainable Growth Rate (SGR) formula that governs physician payment. This two-month delay gives Congress the opportunity to address physician payment reform next year. SCCT will be calling on you to contact your lawmakers on this important issue. Watch for grassroots alerts early in the new year. Your voices count most!
CMS Releases Final 2010 Physician Payment Rule, click here to read more.
CMS Releases Final 2010 Hospital Outpatient Payment Rule, click here to read more.
New Category 1 Codes for Cardiac Computed Tomography
In a sentinel achievement for the specialty, SCCT is pleased to announce New Category 1 Codes for Cardiac Computed Tomography. Effective January 1, 2010, there will be 4 new Category 1 codes to report cardiac computed tomography. This accomplishment represents a significant step forward to achieve broader patient access to this proven technology. To read more click here.
REIMBURSEMENT UPDATE March 2, 2010
Late last night (March 2, 2010), the Senate passed legislation to halt the 21.2 percent Medicare physician payment cut attributable to the SGR, until April 1, 2010. The President is expected to sign the measure. Make sure to contact your U.S. Senators to demand action to reform the Medicare physician payment system. Click here for details.
CMS Rescinds Change Request 6375 (Place of Service [POS] and Date of Service [DOS] Instructions for the Interpretation [Professional Component] and Technical Component of Diagnostic Tests
The Centers for Medicare & Medicaid Services (CMS) has rescinded Change Request (CR) 6375, Transmittal 1873 sent via RO-6657, dated December 11, 2009, and will replace it with another CR in the future, pending further policy clarification on date of service and place of service reporting for the interpretation of diagnostic tests. The revised CR will address the full spectrum of clinical scenarios. The MLN Matters article, MM6375, is also rescinded. Another MLN Matters article will be issued when the new CR is released.
Changes to CMS Requirements for Reporting Place of Service and Date of Service for Interpreting Diagnostic Tests
On December 18th, CMS announced that Transmittal 1823 - Place of Service (POS) and Date of Service (DOS) is rescinded and replaced by Transmittal 1873. Click here to read more.
CMS has instructed its contractors to hold claims containing services paid under the Medicare Physician Fee Schedule (MPFS) for the first 10 business days of January (January 1 through January 15) for 2010 dates of service. Contractors will begin releasing held claims into processing under the fee schedule which implements current law after that 10 day period. This is to allow contractors time to input revised fee schedule and avoid processing claims with the negative 21.2 percent update.
Meanwhile, all claims for services delivered on or before December 31, 2009, will be processed and paid under normal procedures.
Click here to link to the news release on CMS website.
CMS Releases Final 2010 Hospital Outpatient Payment Rule
Late Friday, October 30th, the Centers for Medicare and Medicaid Services (CMS) released the review copy of the 2010 Hospital Outpatient Prospective Payment System (HOPPS) final rule. The Society of Cardiovascular Computed Tomography (SCCT) will be submitting comments to CMS addressing issues of concern by the deadline of Dec. 31, 2009. Please click here to read more.
CMS Releases Final 2010 Physician Payment Rule
On October 30, 2009, the Centers for Medicare and Medicaid Services (CMS) released the 2010 final Medicare physician payment rule. The Society of Cardiovascular Computed Tomography (SCCT) will be submitting comments to CMS addressing issues of concern by end of the 60-day comment period – December 29, 2009. There are several notable components to this rule which are of particular concern to SCCT members, please click here to read more.
Humana Settlement to end soon
Reminder to review your Humana contract before Oct. 19th. The physician protections of the Humana multidistrict litigation class-action settlement agreement end Oct. 19. The termination of the Humana settlement agreement means that Humana no longer has to comply with its settlement terms. If you contract with Humana, we encourage you to review your contract and contact your Humana provider representative to determine how the settlement termination will affect your business relationship with the health insurer.
Health Reform Update - Weiner/Braley Amendment Withdrawn
Dear SCCT Member:
As the Senate Finance Committee continues to mark up its version of health care reform, the House Energy and Commerce Committee reconvened yesterday for expedited consideration of remaining amendments to the health reform bill the Committee reported out prior to the August Congressional District Work Period.
Of note, one of the amendments offered and then withdrawn from consideration, in a victory for patients, was an amendment by Representatives Anthony Weiner (D-NY 9th District) and Bruce Braley (D-IA 1st District). This amendment would have eliminated the Stark law's in-office ancillary services exception which allows advanced diagnostic imaging services to be performed in the physician office setting. We commend Representatives Weiner and Braley for withdrawing this controversial amendment from consideration. We all must to work together to ensure patient access to care and appropriate use of diagnostic medical imaging.
We look forward to continued discussions on this issue. We thank all of you who made your voices heard and continue to be involved in health reform communications to Congress. If you would like to become an active volunteer to contact Congress, please go to www.scct.org and click on "Call to Action" and fill out the SCCT Grassroots Coalition volunteer form. Your voices count most!
Summary - Senate Finance Committee's Draft Health Care Reform Mark.
Please click here to review summary
SCCT Working to Fight Proposed Cuts in Reimbursement
Dear Member -
On Monday, August 31, 2009, SCCT submitted comments to the Centers for Medicare and Medicaid Services (CMS) in opposition to a number of provisions contained in CMS' proposed Medicare Physician Fee Schedule for 2010. Both cardiologists and radiologists are slated for deep cuts in reimbursement under the proposal, largely because of CMS' proposed implementation of new Physician Practice Information Survey (PPIS) data.
We will continue to work on these issues with CMS and will update you on the outcome in early November when CMS publishes the final fee schedule rule. Please view the SCCT comments in full at www.scct.org/advocacy/SCCT2010_PFS_Comments_Final.pdf
CMS Recovery Audit Contractor Program
Overview
RAC Permanent Program: Section 302 of the Tax Relief and Health Care Act of 2006 makes the Recovery Audit Contractor (RAC) Program permanent and requires the Secretary to expand the program to all 50 states by no later than 2010. See below for a link to the text of this legislation and further updates on the CMS website.
The RAC Program's mission is to reduce Medicare improper payments through the efficient detection and collection of overpayments, the identification of underpayments and the implementation of actions that will prevent future improper payments.
CMS RAC Website
Texas Heart Attack Prevention Bill Signed
Texas Governor Rick Perry signed the Texas Heart Attack Prevention Bill (HB1290), the nation's first preventive cardiovascular screening bill for early detection of coronary artery disease. The legislation, which will take effect on September 1, requires Texas insurers to pay up to $200 for a either a non-contrast computed tomography (CT) scan measuring coronary artery calcification, commonly known as a Calcium scoring exam, or ultrasonography for measuring carotid intima-media thickness and plaque.
The final wording of Act HB1290 stipulates that health-benefit providers cover the cost of CT coronary-artery-calcium (CAC) scans and carotid ultrasonography in men between the ages of 45 and 76 and women between the ages of 55 and 76, as well as anyone (at any age) who has diabetes or is deemed to be at intermediate risk or higher for developing CAD, as determined by the Framingham risk score. The test may be conducted every five years by a certified laboratory.
These two non-invasive screening tests have proven by the National Health Institute studies to be strong predictors of those who are vulnerable to a heart attack or stroke. The Texas legislation is the first in the United States to mandate coverage coronary artery calcification.
If you would like to review the legislation, please click here.
United Healthcare Revises Cardiac Computed Tomography (CT), Coronary Artery Calcium Scoring and Cardiac CT Angiography Policy
On June 18th, United Healthcare's Medical Technology Assessment Committee approved a revised Medical Policy for Cardiac Computed Tomography (CT), Coronary Artery Calcium Scoring and Cardiac CT Angiography. The policy was posted on the United Healthcare website July 1st and is available for review here.
Changes to Coverage:
Coronary Artery Calcium Scoring
Coronary artery calcium scoring using electron beam or multi-slice computed tomography 16-slice or greater technology, is proven for the following:
- risk stratification in asymptomatic patients with moderate risk for coronary heart disease (CHD) based on Framingham score
- as a triage tool for symptomatic patients to rule out obstructive disease and avoid an invasive procedure
Coronary artery calcium scoring is unproven for all other indications, including routine screening. The evidence indicates that screening asymptomatic adults for coronary heart disease is ineffective and that the harms may outweigh the benefits.
Cardiac CT angiography
Computed tomography angiography (CTA), using 32-slice or greater technology, is proven for assessing the following:
- detecting coronary artery disease in asymptomatic patients with high risk of coronary heart disease (CHD)1
- to rule out coronary artery disease in symptomatic patients with a low to intermediate pre-test probability of coronary artery disease (CAD)2
- chest pain syndrome following a revascularization procedure (stent placement or angioplasty)
- suspected coronary artery anomaly
- preoperative risk assessment for intermediate or high risk non-cardiac surgery3
- morphology of congenital heart disease, including anomalies of coronary circulation, great vessels and cardiac chambers and valves
- assessment of coronary arteries in patients with new onset heart failure to assess etiology
Computed tomography angiography (CTA) is unproven for the following:
- detecting coronary artery disease in symptomatic patients with a high pre-test probability of CAD2
- assessing coronary arteries in symptomatic patients with previously diagnosed CAD
- post-revascularization procedure to rule out in-stent restenosis or assess bypass grafts in asymptomatic patients
- routine screening in asymptomatic patients or patients at low risk of CAD
Although CTA may be a possibility to rule out in-stent restenosis, routine application of CT to assess patients with coronary stents can currently not be recommended. Visualization of the stent lumen is often affected by artifacts, and especially the positive predictive value is low.
Although CTA may be useful in carefully selected patients with bypass grafts, the inability to reliably visualize the native coronary arteries in patients post-CABG poses severe restrictions to the general use of CT angiography in post-bypass patients.
Coronary CTA should only be considered when the potential risks posed by catheterization outweigh the potential risks posed by the somewhat less accurate detection of clinically significant CAD by CTA. In addition, coronary CTA is not suitable for patients who are likely to require coronary angioplasty or stenting since CTA will not allow these patients to avoid cardiac catheterization in any event, and this is the primary advantage of coronary CTA.
Cardiac CT
Cardiac computed tomography, with or without contrast, using 32-slice or greater technology, is proven for assessing cardiac structure/anatomy for the following:
- pulmonary vein anatomy prior to ablation procedure
- coronary vein mapping prior to placement of biventricular pacemaker or biventricular implantable cardioverter defibrillator
- coronary arterial mapping, including internal mammary artery, prior to repeat sternotomy
- suspected cardiac mass (tumor or thrombus) or pericardial disease in patients with technically limited images from echocardiogram, magnetic resonance imaging (MRI) or transesophageal echocardiogram (TEE)
Cardiac computed tomography, with or without contrast, using 32-slice or greater technology, is proven for assessing cardiac function when the primary procedure with which it is associated is proven.
Additional information Accreditation
United does require participation in the Radiology Notification program if they performing physician has not me the UnitedHealth Premium® quality and cost efficiency designation. Also United requires outpatient imaging sites and providers that bill on a CMS/HICF 1500 or its electronic equivalent, and perform CT long with other imaging modalities to have completed and submitted an application to obtain accreditation. Accreditation applies to global and technical service claims.
Compliance with this policy will become a condition for reimbursement from UnitedHealthcare in the fourth quarter of 2009. No official date has been set, but we will keep you updates as this becomes available. For more information on the accreditation requirements, please click here.
CMS Releases 2010 Proposed Rule
On July 1, 2009, the Centers for Medicare Medicaid Services (CMS) released the proposed Medicare Physician Fee Schedule (PFS) for 2010. CMS projects that the proposed changes would reduce overall Medicare payments to both cardiology and radiology by approximately 11 percent. The projected payment cuts would result from the following policy proposals:
- Conversion Factor: For 2010, CMS is projecting a conversion factor of $28.3208 and a PFS update of -21.5 percent. The conversion factor for 2009 is $36.0666. Congress has taken a series of legislative actions to prevent deep reductions in payment over the last several years. As of this writing, some proposals in Congress call for a 2 or 3 percent positive payment update for physician services. SCCT is working in coalition with others in the House of Medicine to urge Congress to prevent the -21.5 percent cut.
- What does this proposal mean to you? A cut in payment rates for all services provided under Medicare.
- Practice Expense: CMS is proposing changes to practice expense and plans to change the complex reimbursement formula based on data recently obtained from the American Medical Association's (AMA) Physician Practice Information (PPI) Survey. The AMA survey data show steep declines in practice expense for nearly all cardiology and radiology services. With the exception of some evaluation and management services, nearly all services that cardiologists perform would see cuts ranging from 10 percent to more than 40 percent for individual services. For example, cardiac MRI and echocardiography would face cuts of up to 42 percent. Given that cardiovascular CT angiography is reported with Category III tracking codes, the proposed rule does not assign any reimbursement values. We will learn the assigned values when CMS publishes the final fee schedule for 2010, by November 1, 2009. The final rule will provide SCCT and others the opportunity to comment on assigned values for cardiovascular CT angiography.
- What does this proposal mean to you? Additive cuts to those above for the practice expense component (clinical staff, supplies and equipment) of services provided under Medicare.
- Equipment utilization: CMS proposes changes to the formula for calculating the per-procedure cost of medical equipment costing more than $1 million. Specifically, CMS proposes to increase this equipment utilization rate assumption from 50 percent of the time practices are open for business, to 90 percent, thus driving down the practice expense for services using that equipment. At this time CMS does not propose to implement a change for less expensive equipment. However,legislative proposals on Capitol Hill would establish a 75 percent equipment utilization assumption rate spread across all imaging modalities. Sweeping and unsubstantiated changes in equipment utilization will to have a big impact on cardiac CT services. SCCT will provide substantial comments to CMS. In addition, we are in communication with lawmakers about this flawed proposal.
- What does this proposal mean to you? Yet another cumulative cut in practice expense reimbursement rates as CT equipment exceeds the million dollar price determined by CMS.
- Malpractice: CMS proposes to update the malpractice Relative Value Units (RVU) with data from a new survey of specialty-level malpractice premiums. In addition, CMS has proposed a new method for determining malpractice RVUs for technical component services. The proposed new malpractice RVUs would reduce cardiology and radiology payments by 1 percent.
- What does this proposal mean to you? An additive cut to reimbursement rates in 2010.
- Quality: The proposed rule contains a number of provisions to promote improvement in quality of care and patient outcomes through revisions to the Electronic Prescribing Incentive Program (e-Prescribing Program) and the Physician Quality Reporting Initiative (PQRI). Eligible professionals or group practices that meet the requirements of each program in CY 2010 will be eligible for incentive payments for each program equal to 2.0 percent of their total estimated allowed charges for the reporting periods
- What does this proposal mean to you? Potential opportunity for bonus payment from Medicare if initiative requirements are met.
- Accreditation: CMS, in an effort to begin implementation of a statutory provision of last year's Medicare reform law, has proposed detailed requirements to guide the mandatory accreditation of facilities that provide imaging services. This provision applies to advanced diagnostic imaging services including MR, CT, nuclear and PET. Accreditation is mandated to take effect January 1, 2012.
- What does this proposal mean to you? Accreditation is required for CT no later than January 1, 2012.
Overall, the proposed fee schedule represents a real threat to SCCT members and the patients they serve. SCCT will continue to analyze the rule. Be assured we are in close contact with our colleagues in both the cardiology and radiology communities to develop a coordinated plan of action to address these onerous and unreasonable proposals that threaten to severely curtail access to diagnostic imaging services.
We will need your help to fight these cuts to overall reimbursement and imaging services in particular. Please watch for important grassroots calls to action in the coming weeks. You can make a difference!
If you have any questions, please contact Denise Garris (dgarris@scct.org) or Carrie Kovar (ckovar@scct.org).
Medicare RAC Forums
As a reminder, the Medicare RAC program is now permanent and will be expanded to all 50 states by 2010.
Reminder Effective April 6, 2009, New Provider Authentication Requirements for Medicare Telephone and Written Inquiries
As you may have heard from your local Medicare contractor, effective April 6, 2009, the Centers for Medicare & Medicaid Services (CMS) will require providers to provide the following three data elements for authentication when calling either the Interactive Voice Response (IVR) system or a Customer Service Representative (CSR), and on written inquiries:
- The provider's National Provider Identifier (NPI)
- The provider's Provider Transaction Access Number (PTAN)
- The last five digits of the provider's Tax Identification Number (TIN)
Note: Providers will be allowed only three attempts to correctly provide the NPI, PTAN and last five digits of their TIN.
Because of issues with the public availability of previous authentication elements, CMS has addressed the current provider authentication process for providers who use the IVR system or call a CSR. To better safeguard providers' information before sharing information on claims status, beneficiary eligibility and other provider-related questions, CMS has added the last five digits of the provider's TIN as an additional element in the provider authentication process. The IVR system and CSRs will verify that the NPI, PTAN and last five digits of the TIN are correct and belong to the provider before furnishing the requested information.
It is very important that providers and their staffs are aware of this new requirement for provider authentication before contacting Medicare contractors.
Providers may refer to CMS' MLN Matters article MM 6139 for more information.
RBRVS: Resource-Based Relative Value Scale
The American Medical Association (AMA) and specialty societies advocate for fair and accurate valuation for all physician services within the Resource-Based Relative Value Scale (RBRVS). To ensure that physician services across all specialties are well-represented, the AMA established the AMA/Specialty Society Relative Value Scale Update Committee (RUC). The RUC makes annual recommendations regarding new and revised physician services to the Centers for Medicare and Medicaid Services (CMS) and performs broad reviews of the RBRVS every five years. Click here to learn more about how the AMA is helping doctors help patients through physician payment policy and systems.
If you require additional information, please visit the AMA website at www.ama-assn.org/go/rbrvs.
SCCT Endorses FDA Safety Measures Regarding ICRMDs
On July 14, 2008, the U.S. Food and Drug Administration issued a preliminary public health notification alerting healthcare professionals of the possibility that x-rays delivered during diagnostic computed tomography scanning could cause some electronic medical devices to malfunction (http://www.fda.gov/cdrh/safety/071408-ctscanning.html). This notification was prompted by a small number of clinical reports linking adverse events with implanted and external electronic medical devices with exposure to x-rays during computed tomography (CT) scanning. Adverse events included unintended "shocks" from neurostimulators, insulin pump malfunctions, and transient changes in pacemaker output pulse rate. The FDA also noted similar reports in the literature (1, 2, 3). Although there is not yet a comprehensive understanding of the potential risks, the FDA recommends precautionary steps be taken before using CT to image patients with cardiac pacemakers, implantable cardiac defibrillators, neurostimulators, drug infusion pumps (including insulin pumps), cochlear implants, and retinal implants. The following potential risks were identified: 1) generation of spurious signals, including cardiac defibrillation pulses, 2) misinterpretation of signals produced by the x-rays as actual biological signals, 3) missed detection of actual biological signals, 4) resetting or reprogramming of device settings.
Click here to read SCCT's entire statement.
ABN Form Revised for 2008: Must be Used By September 1, 2008
The Advanced Beneficiary Notice is now known as the Advanced Beneficiary Notice of Noncoverage (ABN). The name change was instituted by the Center for Medicare and Medicaid Services (CMS) to more clearly convey the form’s purpose. To learn more, click here.
CMS Announces LCD to Remain in Place for CCTA
The Centers for Medicare and Medicaid Services (CMS) announced late this afternoon (March 12, 2008) that the local coverage determination process (LCD) will be left in place for CCTA. No national coverage determination (NCD) will be adopted at this time.
This is exactly what SCCT requested! Our SCCT leaders and members worked hard to submit comments, meet with CMS, and provide the agency with needed information. SCCT leaders, members, and advocacy consultants worked as a team to bring this issue to the attention of Congress. 79 Members of the House of Representatives ultimately signed a letter to CMS to express concern about the proposed NCD. In addition, almost a dozen U.S. Senators wrote to CMS with their concerns. This is a direct result of our active grassroots involvement!
Click here to read the memo.
Local Coverage Determinations
To view a complete list of your Medicare carrier's LCDs, go to http://www.cms.hhs.gov/mcd/index_lmrp_bystate.asp
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