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The Centers for Medicare and Medicaid Services (CMS) in May released a technical correction to the 2010 Medicare Physician Fee Schedule that resulted in payment increases for myocardial perfusion imaging (MPI) codes, cardiac computed tomography (CT) codes and cardiac catheterization codes, retroactive to Jan. 1. The correction notice also included a minor increase in the Medicare conversion factor (from 36.066 to 36.0791) effective June through December. The corrections to MPI and CT codes address errors made in incorporating RUC recommendations on direct practice expenses (e.g., medical supplies, equipment time) for these services. The errors included incorrect practice expense values for CPT codes 75571 – 75574 and 78451 – 78454. For example, the corrected national average payment for 78452 (single photon emission computed tomography MPI, multiple) is $439, compared to the $379 published in the November Final Rule. The American Society of Nuclear Cardiology, the Society of Nuclear Medicine and the American Medical Association (AMA) identified the errors in the SPECT codes. The Society of Cardiovascular Computed Tomography and the ACC worked with CMS to correct errors in the cardiac CT codes. The correction notice also includes changes to malpractice RVUs for cardiac catheterization services. In the fee schedule, CMS agreed with ACC, the Society for Cardiovascular Angiography and Inter-ventions and the AMA that cardiac cath services should be assigned malpractice RVUs based on the higher surgical risk factor. However, the published RVUs and payment rates did not correctly reflect that policy change. With this notice, CMS has corrected its error. The payment changes — for example, an increase from $235 to $253 for 93510-26 (Left heart catheterization, professional component) — reflect the higher risk associated with invasive procedures. As of this issue of Cardiology, CMS still is drafting instructions for local Medicare carriers, contractors and providers to implement the corrections. CMS must complete and release these instructions before local Medicare carriers can correctly reprocess claims with the new updated payment rates. In the interim, the ACC recommends that members not refile claims until CMS provides these additional instructions. Meanwhile, the College continues to apply pressure to CMS to address the other imaging cuts included in the 2010 Medicare rule. Most importantly, the ACC continues to press for a phase-in of the bundled nuclear codes and is working with members of Congress and CMS to help them under-stand the extent of the cuts, their impact on practices and the need for a formal policy that phases in cuts of a certain magnitude over time.
Under the “Medicare Improvements for Patients and Providers Act of 2008” (MIPPA), suppliers furnishing the technical component of advanced imaging services must be accredited by a designated accreditation organization for purposes of reimbursement as of Jan. 1, 2012. For more information on the requirements and how to prepare, visit the “Advocacy” section of CardioSource.org and click on the “Imaging” issues. The Patient Protection and Affordable Care Act of 2010 (PPACA) includes several near-term requirements that have the potential to increase the burden on physician practices that provide imaging services. The ACC last month sent a letter to the Centers for Medicare and Medicaid Services (CMS) urging the agency to implement several of these requirements in a manner that minimizes the costs and administrative burdens on cardiovascular practices. The letter provides specific recommendations on the following: