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CMS proposes to cut office based SCS trials

nvrsumr

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    Looks like CMS will bundle the SCS L code for office trials but of course not in the hospital or ASC......

    There is a link below to makes public comments to CMS

    Summary of the Issue
    On Friday, July 6, 2012 CMS released the 2013 Medicare Physician Fee Schedule and is proposing changes to coding and reimbursement for Spinal Cord Stimulation (SCS) trialing in an office setting, also referred to as a non-facility setting. The proposed changes also affect coding and reimbursement for disposable leads, which CMS considers resource costs. As such, CMS believes they should be incorporated as non-facility direct Practice Expense (PE) inputs with other disposable medical supplies.
    In their release, CMS stated that CPT code 63650 is frequently furnished in the office setting, but because there are no relative value units (RVUs) for the non-facility setting, it is not priced accordingly. CMS has proposed to establish values for 63650 in an office setting and has requested input from the AMA RVU update committee (RUC) and others to value the code appropriately.
    This information is proposed, and will be finalized based on public input to the proposals. The final rule will be published around November 1, with implementation for 1/1/2013. Comments can be submitted via: http://www.regulations.gov/#!documentDetail;D=CMS-2012-0083-0075 - follow the link and click the blue "Comment Now!" box
    CMS is proposing to:
     Bundle the cost of the lead into the procedure code 63650, and establish appropriate practice expense within the office setting.
     Establish values for physician practice expense for SCS trials in the office setting
     Suggest that L8680 is not the appropriate code for billing for trial leads in the office setting
     Seek comments on the appropriate value of 63650, particularly the non-facility practice expense (supplies, equipment, etc.) RVUs AND the physician work value (time and intensity) in all settings.
     Seek comments or guidance on the appropriate valuation of the supplies (disposable leads) used during 63650 in an office setting.
    CMS is soliciting public feedback on the proposal. What are their questions?
     How should CPT 63650 be valued in the office setting?
     Currently there is an RVU work value established for CPT 63650. What is the appropriate physician time and intensity (RVU work value) to perform this procedure in the office or facility setting?
     What is the correct value for the disposable lead?
     What should be captured within the non-facility practice expense that is different than the facility practice expense for CPT 63650?
     What else should CMS keep in mind when establishing appropriate RVU values for CPT 63650 in the office setting?
    How do I comment?
     Comments are accepted until 4 PM ET on September 4, 2012.
     Comments can be submitted via: http://www.regulations.gov/#!documentDetail;D=CMS-2012-0083-0075 Follow the link and click the blue "Comment Now!" box
    We are collaborating with societies, industry, and individual physicians to respond to this proposal. Medtronic’s reimbursement team can provide more detail on this and other policy proposals, including information on how to respond to the proposed rule. Please contact your local Health Economics Manager for assistance.
    Additional information regarding proposals affecting Medtronic Neuromodulation implantable pump therapies will be available separately from your Health Economics Manager.
    Source: Medicare Physician Fee Schedule (MPFS) 2013 Proposed Rule, p 49 of display version www.cms.gov, July 6, 2012. http://www.gpo.gov/fdsys/pkg/FR-2012-07-30/pdf/2012-16814.pdf p. 14, 77 FR 44734
     

    bedrock

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      Sounds like it's not definitive, but likely.

      Total bull**** that this coding change doesn't apply to hospitals/ASCs.
      I guess all that lobbying and stripper parties were able to preserve the hospital/ASC payments.......

      I do a lot of SCS as second/third opinion. If this rule goes through I may be forced to buy/build an ASC to still get paid for all the work that goes into all those SCS patients.
       
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      Pain Applicant1

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        They're doing this to try and limit abuse. They want to stop people from doing fly by night trials. Some people are opening lead packages and not caring what happens after. I'm not talking about not caring whether the patient goes on to implant, I'm talking about not even caring if the lead is placed properly or placed at all. Doesn't matter because once open, it can be billed. They likely feel that the hospital/ASC setting can better discern who is qualified to actually do stim as privileges are required. Since privileges require at least some type of background check process, the quality of those who perform stim may go up.
         

        PMR 4 MSK

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          Hospitals and ASCs dont lobby together, they are against one another. Hospitals have far larger lobbies and want CMS to crush ASCs.

          5-10 years from now we'll all be hospital drones or retired anyway.
           

          bedrock

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            They're doing this to try and limit abuse. They want to stop people from doing fly by night trials. Some people are opening lead packages and not caring what happens after. I'm not talking about not caring whether the patient goes on to implant, I'm talking about not even caring if the lead is placed properly or placed at all. Doesn't matter because once open, it can be billed. They likely feel that the hospital/ASC setting can better discern who is qualified to actually do stim as privileges are required. Since privileges require at least some type of background check process, the quality of those who perform stim may go up.

            I don't think you can make that argument unless ASC lead payments also go out the window.
            A coffee and $1.25 will get you credentialed at most ASCs, and if you own a sizeable chunk of the ASC, you'll see a big financial benefit from ASC trials.
             

            Pain Applicant1

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              I don't think you can make that argument unless ASC lead payments also go out the window.
              A coffee and $1.25 will get you credentialed at most ASCs, and if you own a sizeable chunk of the ASC, you'll see a big financial benefit from ASC trials.

              Possibly, but I did get this info from someone who lobbied for this. No ASC or hospital affiliation.

              Theoretically it's not supposed to be that easy to be credentialed at an ASC.
               

              Ducttape

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                Sorry to revive old thread....


                Anyone know if there is going to be a continued push towards limiting in-office trials? I believe nothing changed so far...

                I'm article 28, hospital outpatient dept., so not technically office, but am thinking of leaving article 28. Wondering if I won't be able to do stims here - hate to go to surgicenter for them...
                 

                bedrock

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                  Sorry to revive old thread....


                  Anyone know if there is going to be a continued push towards limiting in-office trials? I believe nothing changed so far...

                  I'm article 28, hospital outpatient dept., so not technically office, but am thinking of leaving article 28. Wondering if I won't be able to do stims here - hate to go to surgicenter for them...

                  In-office trials are safe for this year, but I don't expect this CMS push to stop. I expect they'll try to bundle stim trials in the near future. I don't know if it will be just in-office or they'll cut everything outside of a hospital?


                  The CMA people are very short-sighted with this type of approach. They try to cut physician payments for anything performed outside of a hospital, so there is a massive wave of physicians that then go work for hospitals, and subsequently a major increase in hospital charges (for the very same services that used to be provided in office), and as the hospital charge is 1.5x-8x as much for the exact same service, CMS ends up paying much more in the end then if they had simply not cut reimbursement to private practice physicians.

                  When will they learn?
                   
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                  emd123

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                    Here's the weird thing, though. They're trying to push Kypho out of the hospital for some reason, paying $8,000 for a single level and thousands more for add on levels, in-office.

                    WTF?
                     

                    bedrock

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                      Here's the weird thing, though. They're trying to push Kypho out of the hospital for some reason, paying $8,000 for a single level and thousands more for add on levels, in-office.

                      WTF?

                      I bet it costs CMS at least 8,000 for a kypho in hospital.
                      Plus it is a very new code for in-office. I'm sure it will get reduced in a year or so.

                      What is the cost for kypo kit, when doing them in office?
                       
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