ISASS Policy & Advocacy News – January 2018

ISASS Comments on 2018 Final OPPS & ASC Rule
December 28, 2017
Vertebral Columns – Spring 2018
April 9, 2018
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ISASS Policy & Advocacy News for Spine Surgeons

 

News and noteworthy information for January 2018:

  • What’s New in Spine Coding for 2018?
  • RUC Surveys – Assigning Value to Spine Procedures
  • CMS Issues 2018 OPPS & ASC Correction Notice
  • CMS Launches New Data Submission System for the Quality Payment Program
  • CMS Announces Advanced APM Voluntary Bundled Payment Model

 

What’s New in Spine Coding for 2018?

Code changes for all medical specialties went into effect January 1, 2018 as a result of the CPT Editorial Panel process. The American Medical Association (AMA) is responsible for Current Procedural Terminology (CPT) and has convened the CPT Editorial Panel to develop and maintain the nomenclature healthcare providers use to report medical procedures and services. The CPT Editorial Panel meets three times a year to evaluate code change proposals for new and emerging technology and is responsible for reorganizing and maintaining the code set. After codes are created or modified by the CPT Editorial Panel, they go before the Relative Value Update Committee (RUC), also convened by the AMA, to be valued. For more information on the RUC process and how to efficiently complete a RUC survey if you are randomly selected to do so, this 13-minute video prepared by the AMA is a good resource.

The CPT Editorial Panel and the RUC processes are cyclical; code changes approved by the CPT Editorial Panel at the February 2016 meeting, the May 2016 meeting, and the September/October 2016 meeting went into effect on January 1, 2018. The Centers for Medicare and Medicaid Services (CMS) takes the RUC recommendations under consideration when assigning final values to codes and updates its payment policies annually via the Physician Fee Schedule rulemaking. The final rule setting code values and payment rates for 2018 was released by CMS on November 2, 2017.

ISASS joined the AMA’s House of Delegates in June 2014. With a seat in the House of Delegates came the opportunity to participate as advisors to the CPT Editorial Panel and the RUC beginning in calendar year 2015. ISASS strives to represent our membership in all three of these forums and provides this educational coding resource to our membership to prepare for spine coding in 2018 and beyond.

Click here for a look at what’s new in spine coding in 2018.

 

RUC Surveys – Assigning Value to Spine Procedures

In the coming weeks, many of you will be randomly selected by ISASS to complete a RUC (AMA/Specialty Society Relative Value Scale Update Committee) survey to evaluate minimally invasive/percutaneous sacroiliac joint fusion surgery. If you receive a RUC survey via email from ISASS, it is critically important that you complete the survey within the stated timeframe and answer the survey questions based on your own clinical experience. Completing the RUC survey allows ISASS to recommend an accurate work value for the surveyed procedure to the RUC and the Centers for Medicare and Medicaid Services (CMS).

The survey is comprised of questions relating to the “physician work” required to perform the procedure on a typical patient. You will be asked to estimate your professional time necessary to complete the procedure as well as an estimate of the complexity and intensity involved. Additionally, you will also be asked to provide an estimate of the work RVU (Relative Value Unit) for the procedure. This is done by comparing the procedure under review to other procedures that are already valued and have established work RVUs.

RUC surveys must be completed based on your own clinical experience with a typical patient. It must be completed independently without coaching or assistance, with the exception of clarification from ISASS staff. If you are inappropriately contacted regarding a RUC survey, please notify ISASS staff immediately.

In preparation of completing a RUC survey, please watch this 13-minute video prepared by the AMA.

 

CMS Issues 2018 OPPS & ASC Correction Notice

On December 22, the Centers for Medicare and Medicaid Services (CMS) issued a correction to the 2018 Final Hospital Outpatient and ASC rule. As part of the Correction Notice, CMS updated the payment indicators of several codes incorrectly assigned a G2 ASC payment indicator instead of a J8 (device-intensive) ASC payment indicator in the final 2018 rule.

ISASS submitted comments to CMS flagging the potential error. As part of the 2018 Correction Notice, CMS changed the ASC payment indicators for the following two surgical spine codes from G2 back to J8, thereby avoiding a decrease of more than $2,800.00 to ASCs for the procedures:

CPT CodeDescriptorFinal 2018 ASC Payment Indicator2018 Correction Notice ASC Payment IndicatorFinal 2018 Payment Rate2018 Correction Notice Payment RateDifference in Payment Rate from 2018 Final to 2018 Correction Notice
22867Insertion of interlaminar/interspinous process stabilization/distraction device, without fusion, including image guidance when performed, with open decompression, lumbar; single levelG2J8$7,539.67$10,381.09$2,841.42
22869Insertion of interlaminar/interspinous process stabilization/distraction device, without open decompression or fusion, including image guidance when performed, lumbar; single levelG2J8$7,539.67$10,381.09$2,841.42

However, CMS did not change the ASC payment indicator for the following surgical spine code back to J8 from G2, meaning CMS does not believe that the procedure meets its “clinical criteria” for device intensive status. This change in payment indicator results in a decrease of more than $900.00 to ASCs for endoscopic lumbar decompression from 2017 to 2018:

CPT Code DescriptorFinal 2018 Payment Indicator2018 Correction Notice Payment IndicatorFinal 2017 Payment Rate 2018

Correction Notice Payment Rate

Difference in Payment Rate from 2017 Final to 2018 Correction Notice
62380Endoscopic decompression of spinal cord, nerve root(s), including laminotomy, partial facetectomy, foraminotomy, discectomy and/or excision of herniated intervertebral disc; 1 interspace, lumbarG2G2$3,631.80$2,721.37-$910.43

According to CMS policy, procedures must meet the following criteria for device-intensive status:

  1. All procedures must involve implantable devices that would be reported if device insertion procedure were performed;
  2. the required devices must be surgically inserted or implanted devices that remain in the patient’s body after the conclusion of the procedure (at least temporarily); and
  3. the device offset amount must be significant, which is defined as exceeding 40 percent of the procedure’s mean cost.

Please note, these changes do not impact surgeon reimbursements under the Physician Fee Schedule.

 

CMS Launches New Data Submission System for the Quality Payment Program

On January 2, the Centers for Medicare & Medicaid Services (CMS) launched a new data submission system for clinicians participating in the Quality Payment Program (QPP).

You can now submit all of their 2017 Merit-based Incentive Payment System (MIPS) data through one platform on the qpp.cms.gov website. Data can be submitted and updated any time from January 2, 2018 to March 31, 2018, with the exception of CMS Web Interface users who will have a different timeframe to report quality data from January 22, 2018 to March 16, 2018. As data is entered into the system, you will see real-time initial scoring within the MIPS performance categories. Data is automatically saved and your records are updated in real time. Payment adjustments will be calculated based on the last submission or submission update that occurs before the submission period closes on March 31, 2018.

How do you know if you are required to submit data to CMS under the QPP? There are two eligibility look-up tools available to confirm your status in the QPP:

  1. If you think you may be required to report data under the MIPS track of the QPP, you should check your National Provider Identifier (NPI) in the MIPS Participation Status Tool, which will be updated with the most recent eligibility data, to confirm whether you are required to submit data under MIPS for 2017.
  2. If you know you are participating in an MIPS APM or Advanced APM, CMS is working to improve the Qualifying APM Participant (QP) Look-up Toolto include eligibility information for Advanced APM and MIPS APM participants.

CMS encourages you to log-in early to familiarize yourself with the new system. To login and submit data, use your Enterprise Identity Management (EIDM) credentials. To learn more about the QPP data submission system, please review this CMS fact sheet. Visit qpp.cms.gov to explore measures and activities and to review guidance on MIPS, APMs, what to report, and more. Go to the Quality Payment Program Resource Library on CMS.gov to review QPP resources.

 

CMS Announces Advanced APM Voluntary Bundled Payment Model

On January 9, the Centers for Medicare and Medicaid Services (CMS) announced the launch of a new voluntary bundled payment model called Bundled Payments for Care Improvement Advanced (BPCI Advanced). Under traditional fee-for-service payment, Medicare pays providers for each individual service they perform. Under this bundled payment model, participants can earn additional payment if all expenditures for a Medicare beneficiary’s episode of care are under a spending target that factors in quality.

BPCI Advanced will allow participating acute care hospitals and physician group practices to receive a single bundled payment for any of 32 types or episodes of care, including 29 inpatient and three outpatient episodes. A clinical episode will begin at the start of an inpatient admission to an acute care hospital or at the beginning of an outpatient procedure and will end 90 days after the end of the inpatient stay or the outpatient procedure. Participants must bear financial risk, implement care redesign activities and use Certified Electronic Health Records; payments under the model are tied to quality performance.

Specific to spine surgery, qualifying clinical episodes of care include:

  • back & neck except spinal fusion (inpatient & outpatient)
  • cervical spine fusion (inpatient)
  • combined anterior posterior spinal fusion (inpatient)
  • spinal fusion- non-cervical (inpatient)

Importantly, BPCI Advanced will qualify as an Advanced Alternative Payment Model (Advanced APM) under the Quality Payment Program (QPP). In 2015, Congress passed the Medicare Access and Chip Reauthorization Act (MACRA). MACRA requires CMS to implement the QPP, which changes the way Medicare pays physicians. QPP creates two tracks for physician payment – the Merit-Based Incentive Payment System (MIPS) track and the Advanced APM track. Under MIPS, providers have to report a range of performance metrics and then have their payment amount adjusted based on their performance. Under Advanced APMs, providers take on financial risk to earn the Advanced APM incentive payment.

CMS is accepting applications through March 12, 2018 to participate in BPCI Advanced. The performance period for BPCI Advanced starts on October 1, 2018 and runs through December 31, 2023. Click here for more information on BPCI Advanced.