Neurosurgery Coding Alert

Look for a one percent raise for Medicare payments.

When the CMS published the 2015 Physician Fee Schedule Final rule in Nov 2014, it took many by surprise. Have a look at what your neurosurgery practice can expect this year from adjustments to conversion factors, global periods, and telehealth payments.

Big Conversion Factor Cut Hangs in the Balance:

Because the Protecting Access to Medicare Act won’t allow any cuts in the conversion factor through Mar. 31, 2015, CMS has finalized the conversion factor of $35.8013 through that date. Starting April 1, however, many practices will be looking at a conversion factor cut of 21.2 percent.

In addition to the potential 21.2 percent cut, other specialties may see pay cuts whether or not Congress votes to avert that deep discount. Specialties that could see a positive turn include neurosurgery which is expected to enjoy a one percent raise.

“Unfortunately, the mandated reduction of the conversion factor has been an annual risk which for more than a decade has been delayed by one year or more at a time after Congressional action,” says Gregory Przybylski, MD, director of neurosurgery at the New Jersey Neuroscience Institute, JFK Medical Center, Edison.

“However, each of these reprieves has not coincided with a funding mechanism to either eliminate the consequences of the SGR calculation or to support an alternative method to calculate and project annual physician Part B costs. Moreover, with payment cuts on the horizon for failing to participate in meaningful use of electronic medical records or to participate in reporting of value/outcome measures, it becomes difficult for practices to plan hiring and investments when payments are difficult to predict.”

Look for Critical Care Increases: You will see primary changes are in the professional liability RVUs. Although the total RVUs dropped for a level one ED E/M service and remained unchanged for a level two, you will now see increases in total RVUs for levels three four and five as well, as both the critical care codes. “In general, the increase in RVUs for mid and high level ER visits will have limited impact upon neurosurgical practices, since most of the ERm encounters are reported with other codes (e.g., outpatient or admission codes),” Przybylski says. “In contrast, for those performing critical care services on a regular basis, the increase in value for both the initial 60 minutes and additional 30 minutes should provide a favorable benefit.”

Table 1: Critical Care RVUs

You May See Reform in Global Periods

Following through on suggestions that were in the proposed rule, CMS has confirmed that it will phase out global periods. In 2017, all services with 10-day global periods will be assigned 0-day globals, and by 2018, the 90-day globals will fall to 0 days as well.

Because CMS seems to believe that Medicare is wasting cash by paying doctors for services in global periods that include visits the doctors don’t actually perform, CMS will start evaluating whether a better payment model could be created to reimburse doctors for surgical services “that incentivizes care coordination and care redesign across an episode of care,” CMS says in its fact sheet.

Why is it now time for change? According to CMS, the global surgical codes have evolved to include diversity in procedures covered by global periods and the settings in which the procedures and the follow-up care are provided. Additionally there have advances in health care delivery system and business arrangements used by Medicare practitioners. Medicare beneficiaries now also have diverse and different care needs.

“The planned change in global periods remains a hotly debated topic,” Przybylski says. “There are efforts underway to work with CMS to offer alternatives to this strategy, which has many unforeseen consequences on the payment system that would require significant alterations beyond simply changing the global period and asking physicians to report each of their postoperative services individually.”

Telehealth Payments Could Come Your Way

CMS added services as payable under the telehealth benefit, effective Jan. 1.

Meet these requirements: Keep in mind that a phone call won’t allow you to meet the telehealth requirement — you need a two-way, real-time communication system that includes both audio and video, such as a Skype session. “Telephones, facsimile machines and electronic mail systems do not meet the definition of an interactive telecommunications system,” CMS says in the Final Rule. Your physician should determine the eligibility of a telehealth individual and should meet all telehealth requirements as well as the usual Medicare requirements.

“While these services are uncommon, the lack of specialists in many areas has prompted development of telehealth communication that may, for example, allow a physician to perform a stroke evaluation on a patient remotely with audio and video two-way communication,” Przybylski says. Your physician may follow up with a stroke patient for progression of disease. Examples of such assessments include questionnaires evaluating quality of life, patient and staff interviews and observations, attendant and self-care and knowledge, perceived support for health.

Note: To read the complete final rule, visit https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-26183.pdf.