Ophthalmology and Optometry Coding Alert

CMS Downgrades A- and B-Scan Supervision Requirements

Ophthalmologists can now leave more tests to their technicians, freeing up their time for surgery and other services requiring their skills. Thanks to the American Society of Cataract and Refractive Surgery (ASCRS) and the American Academy of Ophthalmology (AAO), many codes have been changed to the general supervision category so that the physician doesn't have to be on premises while the service is performed.
 
Last fall, CMS downgraded physician-supervision requirements for some A-scans and B-scans. Codes 76511 (ophthalmic ultrasound, echography, diagnostic; A-scan only, with amplitude quantification), 76512 (contact B-scan [with or without simultaneous A-scan]), 76513 (anterior segment ultrasound, immersion [water bath] B-scan or high resolution biomicroscopy), 76519 (ophthalmic biometry by ultrasound echography, A-scan; with intraocular lens power calculation) and 76529 (ophthalmic ultrasonic foreign body localization) have been downgraded from personal supervision to direct supervision.
 
Bill the same procedure code that you would have at a higher level of supervision. The only difference is the change in the supervision requirements.
 
Direct supervision means a physician must be accessible to provide assistance by being immediately available. A physician of the group must be on the premises while the service is performed but does not have to be in the room where it is performed. 
 
"Now we can do A-scans when the doctor is in surgery," says John Bell, chief executive officer of Maine Eye Care in Waterville. "These are things a technician generally can do, so why does a doctor have to be there?"
 
The person performing the A-scan or B-scan doesn't have to be a certified technician. "A doctor can direct anyone to do anything when the 'incident to' requirements have been met," Bell says. Medicare requires that the doctor ensure the person has up-to-date training and performs high-quality work and the equipment is in working condition.
 
"I can't think of any testing service that we do in ophthalmology that really needs personal supervision," Bell says. "If a technician can do a fundus angiogram with anaphylactic shock as a potential complication, under direct, but not personal, supervision, then why should other services that don't have any potential serious side effects require direct supervision and not general supervision?"
 
There aren't enough ophthalmologists to do all the A-scans and B-scans that need to be done, says Catherine Cohen, vice president of governmental affairs for the AAO. "The higher level of personal supervision for A-scans and B-scans would fundamentally threaten patient access to these services, which was the basis of the argument we made to CMS," she says.
 
The AAO is pressuring for the downgrading of electro-oculography (92270) and electroretinography (92275) from personal to direct supervision.
 
"We have worked hard to show CMS that these downgrades were appropriate because the greater supervision did not add [...]
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