2014 SVU Annual Convention Advocacy Update: A Review of Current Issues & the VPMN Anne Jones, RN, BSN, RVT, RDMS, FSDMS, FSVU Chair, SVU Advocacy Committee Clinical Instructor in Neurology/Neurosciences Medical University of South Carolina Franklin W. West BSN, RN, RVT, RVS, CHC, FSVU Society for Vascular Ultrasound Director, Practice Support, Compliance and Health Policy Chief Compliance Officer

Overview l The Medicare AAA Screening Benefit l The Vascular Room (93880/2) –Survey Update l Advisory Services –Initial Services Provided l Vascular Practice Management Network –SVU Coding Advisor –Coding & Billing Hotline (unlimited)

2007 AAA Screening Benefit l A one-time AAA screening if: –Referral l from Welcome to Medicare PE (IPPE) and l performed within one year of enrollment for –Males that ever smoked (USPSTF yo) or(USPSTF yo) or –Males & females with a family history of AAA (Congress & CMS)

Barrier Changes l 2007 – Not impacted by Deductible l 2011 – Co-payment Requirement Rescinded l 2014 – IPPE Requirement Rescinded l 2014 – Reimbursement Decrease by ≈ 50% –Not mentioned in the Proposed or Final Rules –Not mentioned in the on-line Addenda –Did you hear the “Surprise!”? (I didn’t …) l So, what happened?

Barrier Changes  2014 – continued …  G0389 (AAA screening code)  HCPCS code (author = CMS, not AMA)  Crosswalk (not surveyed by the AMA RUC)  2007 limited pelvic study (radiology most common)  Effective 2014 revaluation (urology most common)  Decrease in Direct Input from ultrasound room to inexpensive ultrasound machine (≈90% decrease in the direct input for equipment)  Was CMS even aware?  Not until SVU (Anne & Bill) & SVS told them

CMS CY2015 PFS Propose Rule l Re G0389 CMS requests –Comments re practice expense and work –Valuation with full PE RVU methodology l RVUw and Direct Inputs l 2015 (Crystal Ball = Ground Glass) –Maintain RVUw = little change in Prof. Fee –RVUpe revert to CY 2013 adjusted for Budget neutrality = > 100% increase in global and -TC l Thanks to SVU (Anne & Bill) & SVS

93880/ A Case Study (or The Case of the Missing Minutes) l l In 2013, AMA RUC recommended CMS decrease the minutes allocated for the vascular room from 71 minutes in 2013 to 68 minutes in 2014 l l CMS CY 2014 PFS Proposed Rule showed NO change l l CMS CY 2014 Final Rule, published 11/27/13 and effective 1/1/14, disclosed a decrease from 71 to 51 minutes (≈ 25%) – –WHERE ARE THE MISSING 17 minutes? l l The devil is always in the details l l A vague reference to “… refined equipment time to conform with established policies …” – –Impact: roughly a 20% decrease in reimbursement

The Missing 17 Minutes l l Details – –e.g., Greet & Gown; Obtain vital signs; Provide pre-service education / obtain consent; Prepare room, equipment and supplies; Set up duplex scanner; Prepare & position patient, Clean room, Etc. l l CMS does not dispute these things happen – –Clinical staff time remains at RUC recommended (68 min) – –The removal of 17 minutes of room time suggests that CMS believes it is not typically done in the room l l In the absence of CMS notice, we cannot be certain what has been removed from room time

The Missing 17 Minutes l l So, we visit CMS & present our case: – –Response: NONE (regarding 93880/2) l l Not quite – they thanked us for coming to visit l l Nothing in the Proposed Rule – not even a “we’ll thing about it” l l So, what does this mean for the future?

CONSIDER THE FOLLOWING l l AMA RUC revalued and CMS “refined” & with the result being a significant loss of room time (≈ 25% decrease). l l 2014 – AMA RUC revalued (at CMS’s request) the entire “family” of noninvasive vascular diagnostic codes l l 2014 – CMS can be expected to “refine” virtually every other duplex scan code – –Expect hill & CMS visits to avoid this bullet l l Late Breaking News: Congressional Letter to CMS

VPMN l SVU Coding Advisor –Demonstration