Cardiology Coding Alert

2011 Fee Schedule:

Will CMS Slash 2011 Conversion Factor by Over 30 Percent Versus Current Rates?

Plus: Cardiology RVUs could see 2 percent drop.

Another season of nail-biting has passed, waiting to find out whether your Medicare payments will be slashed.

As most practices know, last June Congress voted not only to stave off a 21 percent cut to your Medicare pay, but also to increase your revenue by 2.2 percent. However, that vote only kept the cuts at bay through November 30. Effective December 1, your Medicare pay was set to drop by over 23 percent, unless Congress intervened to reverse the cuts.

The Senate and House passed, and the President signed into law, a measure to delay Medicare's 23 percent cut to the fee schedule conversion factor due to take effect Dec. 1. The delay pushed the possible cut to 2011 for payments with dates of service after Dec. 31, 2010. Then, as of publication time, Congress passed (and the President is expected to sign) a bill extending Medicare reimbursement rates through Dec. 31, 2011.

It had been unclear whether the current Congress would make changes affecting 2011 pay before January, or whether they would leave the issues for the new Congress to handle, said Michael A. Ferragamo, MD, FACS, clinical assistant professor at the State University of New York at Stony Brook, speaking before the bill passed.

If those fixes hadn't passed, here's what would have been in store:

"The calendar year 2011 Physician Fee Schedule conversion factor is $25.5217," noted the 2011 Medicare Physician fee schedule Final Rule (with comment period), printed in the Federal Register published on Nov. 29. This amounted to a dismal 30 percent cut compared to the current rate of $36.8729.

Cardiology Can Expect Extra 2 Percent Cut

In addition to dealing with conversion factor fluctuations, cardiology practices can expect an additional two percent cut due to relative value units (RVUs) and other factors influencing payment, according to table 101 of the rule.

One factor reducing rates for many practices is the Multiple Procedure Payment Reduction (MPPR) on certain imaging procedures.

In 2010, the MPPR on diagnostic imaging services reduces the fee for the technical component of imaging performed on contiguous body parts, meaning those that fall within the same family of codes. Effective Jan. 1, 2011, CMS will combine the 11 advanced imaging families into a single family. Result: Medicare will pay the full TC rate for the procedure with the highest priced TC, but CMS will pay 50 percent for each additional procedure.

Take note: As mentioned, the reduction applies only to the TC portion, not the professional component. In addition, the reduction applies only "when two or more services on the list are furnished to the same patient in a single session," according to MLN Matters article MM6993 (www.cms.gov/MLNMattersArticles/downloads/MM6993.pdf).

You can see the list of codes subject to the MPPR at www.cms.gov/Transmittals/downloads/R738OTN.pdf. Among the codes are several cardiac MRI and cardiac CT codes you should watch for:

  • 75557 -- Cardiac magnetic resonance imaging for morphology and function without contrast material
  • 75559 -- ... with stress imaging
  • 75561 -- Cardiac magnetic resonance imaging for morphology and function without contrast material(s), followed by contrast material(s) and  further sequences
  • 75563 -- ... with stress imaging
  • 75571 -- Computed tomography, heart, without contrast material, with quantitative evaluation of coronary calcium
  • 75572 -- Computed tomography, heart, with contrast material, for evaluation of cardiac structure and morphology (including 3D image postprocessing, assessment of cardiac function, and evaluation of venous structures, if performed)
  • 75573 -- Computed tomography, heart, with contrast material, for evaluation of cardiac structure and morphology in the setting of congenital heart disease (including 3D image postprocessing, assessment of LV cardiac function, RV structure and function and evaluation of venous structures, if performed).

Resource: You can search the Federal Register for the final rule here: www.gpoaccess.gov/fr/.

The "Final Rule" published Nov. 29, 2010, was written under law at that time, said CMS's Amy Bassano during a Nov. 16 CMS Open Door Forum. She indicated that if the law were to change, as it now has, CMS "would put out revised files and rates to reflect any changes in the law." So stay tuned.