ED Coding and Reimbursement Alert

The CMS 2015 Proposed Rule estimates there will be a slight increase in emergency physician payments next year.

Release of the CMS proposed rule offers a preview of what you might see implemented in the 2015 physician fee schedule. Among the issues you’ll want to monitor are changing payment policies for secondary radiology studies and global periods for common ED procedures.

Expect More Money But Don’t Get Too Excited

CMS estimates that changes in the proposed physician fee schedule rule would increase Medicare reimbursement approximately one percent for emergency medicine, assuming there is another patch or finally a permanent fix to the SGR-driven conversion factor reductions looming over medicine for the past decade. “The increase is attributable to positive changes in the Professional Liability Insurance (PLI) component of the RBRVS equation for ED E/M services,” states Michael Granovsky, MD, CPC, FCEP, President of Logixhealth, a national ED billing company. There are no expected changes to the work RVUs for these codes for 2015. 

Global Surgical Package Could Be History 

Because of questions about how many post-op E/M visits following procedures are typically taking place, and who exactly is performing them, CMS has been exploring eliminating the global surgical package concept. Movement to alternative payment models and the need to track RVUs is also behind this move.

The skinny for ED coders: If CMS restricts the global package to pre-operative and operative services; you would report any follow-up services separately, based on the place of service and the E/M documentation guidelines. 

The master plan: CMS is proposing to retain the global periods for surgical services in 2015-16, transition all of the 10-day global periods in 2017 to zero days and all of the 90-day global periods to zero days in 2018.

“We saw a preview of what this might look like in 2012 when the simple laceration repair codes went from 10 day to zero day global periods,” says Granovsky. “It would allow reporting an additional ED visit if the patient returned to the ED for follow-up care. However, large co-payments for ED visits might make that practice uninviting for many insured patients”, he predicts. 

Expect to Report Subsequent Diagnostic Radiology Study Interps 

CMS has asked for comments on how to handle payments for secondary diagnostic radiology interpretations.  For example, if a provider asks for a second opinion an additional interpretation of a single diagnostic study might be required.  

What this means to you: This issue is important to emergency physicians because of a long standing concern over the question of contemporaneous interpretations that typically take place in the ED and interpretations provided later by another provider after the diagnosis and treatment of the patient was completed, explains Granovsky. CMS has asked for input on when, how and for what tests it should pay for subsequent diagnostic radiology services.  

Stay tuned: The final rule for the 2015 Medicare Fee Schedule will be released on or about Nov.1, 2014. Look for the details in ED Coding & Reimbursement Alert on CMS’ final polices on these issues and the final RVU allocations for all the services in the Medicare code set.