CMS Eliminates Consultation Codes – FAQs, Crosswalk and Guidance Available
In the final 2010 physician fee schedule, the Centers for Medicare & Medicaid Services (CMS) eliminated the use of all consultation codes (inpatient and office/outpatient codes for various places of service except for telehealth consultation G-codes) on a budget-neutral basis. Instead, CMS increased the work relative value units (RVUs) for new and established office visits, as well as initial hospital and initial nursing facility visits.
Recently, CMS released Transmittal 1875 and MLN Matters 6740 which provides guidance to practices on how to bill for services for Medicare Part B patients now that consultation codes have been eliminated. CMS announced that the modifier to distinguish the admitting physician from other physicians who may furnish care is “-AI.” The admitting physician should append the “-AI” modifier along with initial visit codes to their claims while other physicians who perform initial evaluations should only bill the appropriate evaluation and management (E/M) code. CMS instructs providers to select the appropriate E/M codes based on the content of services provided and not the level of documentation. According to agency, documentation should merely support the level of services provided. CMS advises practices to take time and/or controlling factors into consideration when determining the level of service provided.
ASA Comments on 2010 Physician Fee Schedule
The American Society of Anesthesiology recently posted their comments regarding the 2010 Medicare Physician Fee Schedule.
- Medicare Anesthesiology Teaching Rule Payment Update– Beginning January 2010, CMS will provide full Medicare payment when a teaching anesthesiologist oversees anesthesiology residents on two overlapping cases, consistent with the Medicare Anesthesiology Teaching Funding Restoration Act of 2007, which became law last year.
- Removal of Physician-Administered Drugs for Purposes of Computing Update – CMS is proposing to remove physician-administered drugs from the definition of “physician services” for purposes of computing the physician update formula.
- Physician Payment Update – Under the proposed rule, and consistent with current law, CMS plans to implement the slated rate reduction of -21.5% for CY 2010. Since 2003, however, Congress has acted to avert significant reductions in Medicare physician payments, with the latest of these interventions occurring last July via the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA). MIPPA provided physicians with a 0.5% update for the remainder of 2008 followed by a 1.1% update through December 31, 2009, thereby preventing what was at the time a projected 10.6% Medicare payment reduction.
- Physician Payment Refinements to Practice Expense (PE) – CMS proposes several changes intended to refine Medicare payments to physicians, which are expected to increase payment rates for primary care and other physicians, including anesthesiologists. The proposals include an update to the PE component of physician fees. For 2010, CMS is proposing to include data about physicians’ practice costs from a new survey, the Physician Practice Information Survey (PPIS), designed and conducted by the American Medical Association (AMA) and over 60 medical specialty societies including ASA.
- Physician Quality Reporting Initiative (PQRI) –For 2010, participants may earn an incentive payment of 2.0% of the eligible professional’s estimated total allowed charges for covered PFS services under Medicare Part B provided during the reporting period. For the CY 2010 PQRI, there are a number of proposed reporting options and reporting periods available. Key changes for CY 2010 include:
- Proposed inclusion of the Perioperative Temperature Management measure, which would provide a third measure for anesthesiologists (including Measures 30 (Timing of Prophylactic Antibiotics) and 76 (Prevention of Catheter-Related Bloodstream Infections: Central Venous Catheter Insertion Protocol);
- Implementing provisions of MIPPA that would enable group practices to qualify for a 2010 PQRI incentive payment based on a determination at the group practice level, rather than at the individual EP level, that the group practice has satisfactorily reported data on PQRI quality measures;
- Adding an electronic health record (EHR)-based reporting mechanism to promote the adoption and use of EHRs and to provide both eligible professionals and CMS with experience on EHR-based quality reporting.
