CODING Q&A

Procedures Can Be Performed in ASCs But Office May Be a Better Choice

ANSWERS PROVIDED BY RIVA LEE ASBELL

Q. Which retina procedures can be performed in an ASC and be reimbursed by Medicare? We have just received our CON.

A. This is a critical question for 2009 because Medicare changed the entire ASC payment methodology last year and many ASCs are looking to incorporate retinal procedures.

One of the main differences between the old and new systems is that the old system was "inclusionary," whereas the new system's list is best described as "exclusionary."

What does that mean? The inclusionary list enumerated a number of procedures that could be paid to the facility. If a given procedure (such as a procedure with a new CPT code) was not on the ASC list, then the facility could not bill for it until such time as it was added to the list. Moreover, the patient could not be billed since it was a covered procedure.

The new system assumes all procedures with a CPT code — encompassing Category I, II, and III codes — are included unless there is too great a risk to the patient to be performed on an outpatient basis. The list is to be updated quarterly. Exclusions are found in Addendum E in the Federal Register and Addendum EE on the Medicare Web site.

The full list of approved procedures is found in the Federal Register in the final rules of OPPS (Outpatient Prospective Payment System — November 27, 2007) and ASCs. You can purchase the Federal Register from the Government Printing Offices (202-512-1800). Physicians fee schedule is Volume I and ASC is Volume II. The list is also available online at http://www.access.gpo.gov/su_docs/fedreg/a071127c.html.

More will be written about retinal ASC reimbursement in future issues, but here's a warning — give serious consideration before deciding to move all your office-based procedures, such as intravitreal injections, to the ASC for convenience. The surgeon will receive less financial reimbursement compared to the procedure being performed in the office. Medicare is trying to avoid migration of some procedures to the ASC. Thus, the financial penalty.

Q. With an ever-increasing volume of patients requiring intravitreal injections, we are considering doing our injections at an adjacent ASC. We do not own it but our physicians operate there and are investors. We are considering doing an "injection day" in the ASC, which we feel will be more controlled as opposed to a hectic clinic setting, better prep to help decrease the risk of endophthalmitis, and the ability to perform AC paracentesis ("AC tap") under the scope to reduce the risk of elevated IOP. I would appreciate any thoughts on this matter with regard to practicality, coding and reimbursement issues, Medicare concerns, etc. The way I see it, the MD would bill for the injection as usual and the ASC would bill for the AC tap.

A. With the new ASC payment reform, many physicians are considering performing their intravitreal injections in the ASC rather than in the office. Under the new system, this procedure (CPT code 67028) is considered one that was originally office-based, and thus the reimbursement for the physician is lower when performed in the ASC. For Empire Medicare as an example: If performed in the office the reimbursement is $207.49, and if performed in the ASC (a facility) it is $157.10.

When procedures are performed in an ASC, there is a fee schedule for the reimbursement to the facility. Physicians have a different fee schedule with differentiation in payment for some procedures when they are performed in the office vs performed in the facility. So, you can "bill for the injection as usual" but your payment is based on where the procedure was performed.

The paracentesis has a physician reimbursement of $145.84 when performed in the office and $122.51 when performed in the ASC (Empire Medicare). RP

CPT codes copyright 2008 American Medical Association.