2014 SVU Annual Convention Advocacy Update: A Review of Current Issues & the VPMN

1. 2014 SVU Annual ConventionAdvocacy 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

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

3. 2007 AAA Screening Benefit • A one-time AAA screening if: • Referral • from Welcome to Medicare PE (IPPE) and • performed within one year of enrollment for • Males that ever smoked • (USPSTF 65-75 yo) or • Males & females with a family history of AAA (Congress & CMS)

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 Barrier Changes • 2007 – Not impacted by Deductible • 2011 – Co-payment Requirement Rescinded • 2014 – IPPE Requirement Rescinded • 2014 – Reimbursement Decrease by ≈ 50% • Not mentioned in the Proposed or Final Rules • Not mentioned in the on-line Addenda • Did you hear the “Surprise!”?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

5. 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

6. CMS CY2015 PFS Propose Rule • Re G0389 CMS requests • Comments re practice expense and work • Valuation with full PE RVU methodology • RVUw and Direct Inputs • 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 • Thanks to SVU (Anne & Bill) & SVS

7. 93880/93882 - A 2013-2014 Case Study(or The Case of the Missing Minutes) • In 2013, AMA RUC recommended CMS decrease the minutes allocated for the vascular room from 71 minutes in 2013 to 68 minutes in 2014 • CMS CY 2014 PFS Proposed Rule showed NO change • 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? • The devil is always in the details • A vague reference to “… refined equipment time to conform with established policies …” • Impact: roughly a 20% decrease in reimbursement

8. 93880 93882The Missing 17 Minutes • 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. • 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 • In the absence of CMS notice, we cannot be certain what has been removed from room time

9. 93880 93882The Missing 17 Minutes • So, we visit CMS & present our case: • Response: NONE (regarding 93880/2) • Not quite – they thanked us for coming to visit • Nothing in the Proposed Rule – not even a “we’ll thing about it” • So, what does this mean for the future?

10. CONSIDER THE FOLLOWING • 2013 - AMA RUC revalued and CMS “refined” 93880 & 93882 with the result being a significant loss of room time (≈ 25% decrease). • 2014 – AMA RUC revalued (at CMS’s request) the entire “family” of noninvasive vascular diagnostic codes • 2014 – CMS can be expected to “refine” virtually every other duplex scan code • Expect hill & CMS visits to avoid this bullet • Late Breaking News: Congressional Letter to CMS

11. VPMN • SVU Coding Advisor • Demonstration