CMS originally claimed, and ADVOCATE originally reported, that the overall impact of the 2017 MPFS finalized changes to radiology be a 1 percent decrease, while interventional radiology would see an aggregate decrease of 7 percent.
These proposed cuts in interventional radiology have been largely mitigated as a result of detailed comments provided to CMS on the valuation of new and revised interventional radiology CPT codes. CMS increased the RVUs for these codes in response to the comments. It is important to note that the revised timeline for valuation of new and revised CPT codes allowed comments to be received during the proposed rule comment period. Under the previous timeline, CMS would have proposed “interim final” RVUs in the final rule and the 7 percent reimbursement reduction would have been realized in 2017 with the first opportunity to be adjusted in 2018.
In addition, interventional radiology will benefit from changes in the coding for moderate sedation in 2017. Previously, moderate sedation was bundled into many procedure codes that were identified in the CPT book with a bullseye symbol. The bullseye indicated that the code was not separately reimbursable. In 2017, the bullseye and the existing moderate sedation codes have been deleted and replaced with a new set of codes that may be billed separately from the procedure.
99151 – Moderate sedation, same physician, first 15 minutes, less than 5 years’ old
99152 – Moderate sedation, same physician, first 15 minutes, age 5 or older
99153 – Moderate sedation, same physician each additional 15 minutes
99155 – Moderate sedation, different physician, first 15 minutes, less than 5 years’ old
99156 – Moderate sedation, different physician, first 15 minutes, age 5 or older
99157 – Moderate sedation, different physician each additional 15 minutes
Accordingly, it is more crucial than ever to properly documentation moderation sedation in the radiologists’ dictation. The codes are based on intraservice time, which must be clearly documented. Intraservice time and work is defined as the continuous face to face presence of the physician or other qualified health care professional with the patient and requires monitoring of the patient’s response to the sedation agent. ADVOCATE will provide additional information and documentation guidelines on the new codes in the near future in an upcoming webinar.
As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.
Kirk Reinitz, CPA