The Centers for Medicare and Medicaid Services (CMS) released the 2018 Hospital Outpatient Prospective Payment System (HOPPS) Final Rule on November 1, 2017. CMS made “minor reassignments” (their language) to existing Ambulatory Payment Classifications (APC), resulting in devastating cuts, up to 47% reduction, in reimbursement for four vascular codes.
Representatives from the Society for Vascular Ultrasound and the Society for Vascular Medicine met with CMS staff by conference call on Monday, November 20th. The purpose of the call was to express our deep concerns over the reassignments made to the existing CY 2017 APC groupings, and to see if a mistake was made in the Final Rule.
Specifically, we addressed the negative effects of reassigning the following vascular lab codes from APC 5523 (Level 3) to APC 5522 (Level 2):
- 93880 (Duplex scan of extracranial arteries; complete bilateral study)
- 93930 (Duplex scan of upper extremity arteries or arterial bypass grafts; complete bilateral study)
- 93978 (Duplex scan of aorta, inferior vena cava, iliac vasculature, or bypass grafts; complete study)
- 93886 (Transcranial Doppler study of the intracranial arteries; complete study)
As part of our call, SVU’s regulatory counsel outlined arguments against the reassignments noting inconsistencies with CMS’s policies. SVU and SVM representatives shared member concerns and discussed the panic over these extreme cuts. We focused on the impact on provision of care as well as the inability to keep doors open in many practices.
In addition to our efforts, Society for Vascular Surgery leaders made visits on Capitol Hill to members who are physicians and/or on health committees. They also sent personal letters outlining the impact of such deep cuts on their practices.
CMS has responded to our concerns, stating “if an error has been made for one or more of the CPT codes, the error would be corrected through a correction notice. The correction notice would be issued through the Office of the Federal Register on or before January 1, 2018”. At this time, we are monitoring for correction notices and will notify the membership as we learn more.
I would also like to take this opportunity to thank those individuals and groups who have contributed to the Advocacy Fund. If you have not made a contribution, please consider doing so today. Your contributions are crucial to our efforts.
Wishing you a very Merry Christmas,
Kelly Byrnes, BS, RVT, FSVU
Advocacy Chair and SVU Treasurer