Podiatry Coding & Billing Alert

Estimated impact of podiatry payments is flat for 2017.

The Centers for Medicare & Medicaid Services (CMS) published its Medicare Physician Fee Schedule (MPFS) proposals in the Federal Register on July 7, which included payment policies, reimbursement rates, and quality provisions. The estimated fiscal impact on total allowed charges is such that overall podiatry payments should remain about the same in 2017. That is consistent with the estimate for all Medicare physician charges. However, there are some winning and losing specialties.

For example: Family practice is estimated to get a three percent increase and interventional radiology can expect a seven percent overall decrease. Most other specialties are in the plus or minus one percent range, but remember rounding at this level can make a big difference in the estimates between being minus one percent, even, or plus one percent, says Michael A. Granovsky, MD, CPC, FACEP, President of LogixHealth, an ED coding and billing company in Bedford, MA.

Impact of Conversion Factor on Podiatry

The podiatry conversion factor (CF) for 2017 is $35.7751. The 2017 CF does not reflect any changes based on the required targeted reductions in misvalued codes, since the proposed adjustments to the relative values of misvalued codes is estimated to exceed the 0.5 percent target.

Refinement of Chronic Care Coordination Codes and Global Periods Are Still in Play

CMS proposes a number of coding and payment changes in the MPFS including moderate sedation codes and chronic care management. The chronic care coordination codes have been through several refinements over the years and still have zero RVU assigned to them in 2016.

Expect separate payments for codes describing chronic care management for patients with greater complexity if the proposed changes become final. You’ll also see several changes to reduce the administrative burden associated with the chronic care management codes in order to remove potential barriers to furnishing and billing for these important services.

For CY 2017, CMS proposes changing the procedure status for CPT^® codes 99487 (Complex chronic care management services, with the following required elements: multiple [two or more] chronic conditions expected to last at least 12 months, or until the death of the patient… 60 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month) and 99489 ( … each additional 30 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month).

Under the proposed rule, these codes will change from B (bundled) to A (active), and adopt the RUC-recommended work values of 1.00 RVUs for code 99487 and 0.50 RVUs for code 99489, says Granovsky.

Collecting Data on Resources Used in Furnishing Global Services

When Section 523 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was passed and enacted, the Act prohibited CMS from implementing the policy under which it would have valued the surgery or procedure to include all services furnished on the day of surgery, and then would have subsequently paid separately for visits and services furnished after the day of the procedure. Instead, MACRA requires the agency to gather data on visits in the post-surgical period that could be used to accurately value these services.

In the 2017 proposed rule, CMS suggests a data collection strategy, including claims-based data collection and a survey of 5,000 practitioners, to gather data on the activities and resources involved in furnishing these services. That data will then be considered in future Medicare notices and comment rulemaking.

The impact on procedures with 90-day global period could become simplified under a 0-day global construct. You would no longer need to use modifier 54 (Surgical care only) to indicate that no follow up care is expected to be provided. However, keep in mind that there would likely be a reduction in the payment as well, similar to what was seen with the simple laceration codes, Granovsky warns.

Telehealth turnaround: With the rise and necessity of telehealth, CMS intends to allow several codes to be allowed under this growing service. Those areas affected will be advanced care planning, end-stage renal disease (ESRD) related services for dialysis, and critical care consultations, introducing new Medicare G-codes for the consultations.

Sedation services revised: Past rules brought about new sedation codes created by the AMA’s CPT^® editorial panel at CMS’ request. Now, CMS wants to add values for the new CPT^® moderate sedation codes while streamlining the process of valuation for the procedural codes that utilize moderate sedation. These changes will likely affect the way you code and are paid for claims of moderate sedation.

Endnote: Keep in mind these are but a few of the many proposals that CMS is looking at for CY 2017. As always, the public’s input is key to the eventual final rulings and changes to the proposals.

The 2017 Medicare PFS Proposed Rule can be found at: https://www.federalregister.gov/articles/2016/07/15/2016-16097/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions.