dwaldman
True Blue
Below is my formal comment to CMS regarding the removal of CPT 00670 from the inpatient only list for 2019 OPPS/ASC Final Rule. We had received a denial in the past for ACDF procedure with instrumentation where it was performed on observation basis since this typically an overnight procedure and does not qualify for the two midnight rule and CPT 22845 had been removed from the IPO list with the last couple of years. The insurance carrier used Medicare's inpatient only list which is for hospital to state the professional claim could not be billed with place of service 22 for CPT 00670 because it was an inpatient only procedure according to CMS. So I requested them to remove it from the IPO list and now the final rule has come out, they have accepted the request.
July 26,2018
Your comment was submitted successfully!
Comment Tracking Number: 1k2-94hv-zwdm
Your comment may be viewable on Regulations.gov once the agency has reviewed it. This process is dependent on agency public submission policies/procedures and processing times. Use your tracking number to find out the status of your comment.
Agency: Centers for Medicare Medicaid Services (CMS)
Document Type: Rulemaking
Title: Hospital Outpatient PPS Policy Changes and Payment Rates and Ambulatory Surgical Center Payment System Policy Changes and Payment Rates CMS-1695-P
Document ID: CMS-2018-0078-0001
Comment:
In regards to the Inpatient only list, I believe CPT 00670 should be removed from the inpatient only list. There were many spinal instrumentation codes previously removed from the inpatient list that CPT 00670 corresponded too. Now that the majority of spinal instrumentation codes have been removed from the inpatient only, it seems that the corresponding anesthesia code to bill in conjunction with these services should also be removed.
________________________________________________
https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-24243.pdf
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
42 CFR Parts 416 and 419
[CMS-1695-FC]
RIN 0938-AT30
Medicare Program: Changes to Hospital Outpatient Prospective Payment and
Ambulatory Surgical Center Payment Systems and Quality Reporting Programs
AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS
___________________________________________________
Comment: Several commenters recommended the removal of several procedures not originally proposed by CMS for removal from the IPO list for CY 2019. These
recommended procedures related to other procedures that were recently removed from the IPO. In addition, several commenters recommended the removal of all orthopaedic,
arthroplasty, and joint replacement procedures from the IPO list. T
Table 48 below contains the procedures that were explicitly requested by the commenters to be removed
from the IPO list for CY 2019.
TABLE 48.—PROCEDURES REQUESTED BY COMMENTERS TO BE REMOVED FROM THE INPATIENT ONLY LIST FOR CY 2019
CPT Code Descriptors
00670 Anesthesia for extensive spine and spinal cord procedures (eg, spinal instrumentation or vascular procedures)
63265 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; cervical
63266 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; thoracic
63267 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; lumbar
63268 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; sacral
Response: We appreciate the diligence that commenters continue to show in proposing changes to the IPO list. For the CY 2019 OPPS, we believe that it is appropriate to remove the procedure described by CPT code 00670 from the IPO list, as
recommended by the commenters. We refer readers to the CY 2017 OPPS/ASC final rule with comment period (81 FR 79695 through 79696) in which CMS removed six
related codes (four spine procedure codes and two laryngoplasty codes) from the IPO list for CY 2017. We believe that the procedure described by CPT code 00670 is appropriate
for removal from the IPO list because it relates to the following codes that CMS removed from the IPO list in CY 2017: CPT code 22840 (Posterior non-segmental
instrumentation (eg, Harrington rod technique, pedicle fixation across 1 interspace, atlantoaxial transarticular screw fixation, sublaminar wiring at C1, facet screw fixation)
(List separately in addition to code for primary procedure)); CPT code 22842 (Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and
sublaminar wires); 3 to 6 vertebral segments (List separately in addition to code for primary procedure)); CPT code 22845 (Anterior instrumentation; 2 to 3 vertebral
segments (List separately in addition to code for primary procedure)); and CPT code 22858 (Total disc arthroplasty (artificial disc), anterior approach, including discectomy
with end plate preparation (includes osteophytectomy for nerve root or spinal cord decompression and microdissection); second level, cervical (List separately in addition to
code for primary procedure)). We also believe that this procedure is being performed in numerous hospitals on an outpatient basis. Accordingly, we are removing the procedure
described by CPT code 00670 from the IPO list for CY 2019. Because this spine procedure code is an add-on code, in accordance with the regulations at
42 CFR 419.2(b)(18), under the OPPS, this procedure is packaged with the associated procedure and assigned status indicator “N” (Items and Services Packaged into APC
Rates) for CY 2019. With respect to the commenters’ recommendation that we remove CPT code 63265 (Laminectomy for excision or evacuation of intraspinal lesion other than
neoplasm, extradural; cervical), CPT code 63266 (Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; thoracic), CPT code
63267 (Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; lumbar), and CPT code 63268 (Laminectomy for excision or
evacuation of intraspinal lesion other than neoplasm, extradural; sacral) from the IPO list, we intend to continue to review these procedures and the appropriateness of the potential
removal from the IPO list for subsequent rulemaking. In regard to the commenters’ recommendation to remove all orthropaedic, arthroplasty, and joint replacement procedures from the IPO list, we do not believe that
we have sufficient data to support removal of all orthopaedic, arthroplasty, and joint replacement procedures from the IPO list. However, we encourage stakeholders to
submit specific procedures, along with evidence, to support their requests for removal from the IPO list. In conclusion, the complete list of procedure codes that are placed on the IPO list
for CY 2019 is included as Addendum E to this CY 2019 OPPS/ASC final rule with comment period (which is available via the Internet on the CMS website).
Table 49 below contains the final changes that we are making to the IPO list for CY 2019.
TABLE 49.—CHANGES TO THE INPATIENT ONLY LIST FOR CY 2019
CY 2019 CPT Code CY 2019 Long Descriptor Action CY 2019 OPPS APC Assignment CY 2019 OPPS Status Indicator
31241 Nasal/sinus endoscopy, surgical; with ligation of sphenopalatine artery Removed from IPO list
01402 Anesthesia for open or surgical arthroscopic procedures on knee joint; total knee arthroplasty
0266T Implantation or replacement of carotid sinus baroreflex activation device; total system (includes generator placement, unilateral or bilateral lead placement,
intra-operative interrogation, programming, and repositioning, when performed).
00670 Anesthesia for extensive spine and spinal cord procedures (eg, spinal instrumentation or vascular procedures) Removed
C9606 Percutaneous transluminal revascularization of acute total/subtotal occlusion during acute myocardial infarction, coronary artery or coronary
artery bypass graft, any combination of drug-eluting intracoronary stent, atherectomy and angioplasty, including aspiration thrombectomy when
performed, single vessel
July 26,2018
Your comment was submitted successfully!
Comment Tracking Number: 1k2-94hv-zwdm
Your comment may be viewable on Regulations.gov once the agency has reviewed it. This process is dependent on agency public submission policies/procedures and processing times. Use your tracking number to find out the status of your comment.
Agency: Centers for Medicare Medicaid Services (CMS)
Document Type: Rulemaking
Title: Hospital Outpatient PPS Policy Changes and Payment Rates and Ambulatory Surgical Center Payment System Policy Changes and Payment Rates CMS-1695-P
Document ID: CMS-2018-0078-0001
Comment:
In regards to the Inpatient only list, I believe CPT 00670 should be removed from the inpatient only list. There were many spinal instrumentation codes previously removed from the inpatient list that CPT 00670 corresponded too. Now that the majority of spinal instrumentation codes have been removed from the inpatient only, it seems that the corresponding anesthesia code to bill in conjunction with these services should also be removed.
________________________________________________
https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-24243.pdf
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
42 CFR Parts 416 and 419
[CMS-1695-FC]
RIN 0938-AT30
Medicare Program: Changes to Hospital Outpatient Prospective Payment and
Ambulatory Surgical Center Payment Systems and Quality Reporting Programs
AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS
___________________________________________________
Comment: Several commenters recommended the removal of several procedures not originally proposed by CMS for removal from the IPO list for CY 2019. These
recommended procedures related to other procedures that were recently removed from the IPO. In addition, several commenters recommended the removal of all orthopaedic,
arthroplasty, and joint replacement procedures from the IPO list. T
Table 48 below contains the procedures that were explicitly requested by the commenters to be removed
from the IPO list for CY 2019.
TABLE 48.—PROCEDURES REQUESTED BY COMMENTERS TO BE REMOVED FROM THE INPATIENT ONLY LIST FOR CY 2019
CPT Code Descriptors
00670 Anesthesia for extensive spine and spinal cord procedures (eg, spinal instrumentation or vascular procedures)
63265 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; cervical
63266 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; thoracic
63267 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; lumbar
63268 Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; sacral
Response: We appreciate the diligence that commenters continue to show in proposing changes to the IPO list. For the CY 2019 OPPS, we believe that it is appropriate to remove the procedure described by CPT code 00670 from the IPO list, as
recommended by the commenters. We refer readers to the CY 2017 OPPS/ASC final rule with comment period (81 FR 79695 through 79696) in which CMS removed six
related codes (four spine procedure codes and two laryngoplasty codes) from the IPO list for CY 2017. We believe that the procedure described by CPT code 00670 is appropriate
for removal from the IPO list because it relates to the following codes that CMS removed from the IPO list in CY 2017: CPT code 22840 (Posterior non-segmental
instrumentation (eg, Harrington rod technique, pedicle fixation across 1 interspace, atlantoaxial transarticular screw fixation, sublaminar wiring at C1, facet screw fixation)
(List separately in addition to code for primary procedure)); CPT code 22842 (Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and
sublaminar wires); 3 to 6 vertebral segments (List separately in addition to code for primary procedure)); CPT code 22845 (Anterior instrumentation; 2 to 3 vertebral
segments (List separately in addition to code for primary procedure)); and CPT code 22858 (Total disc arthroplasty (artificial disc), anterior approach, including discectomy
with end plate preparation (includes osteophytectomy for nerve root or spinal cord decompression and microdissection); second level, cervical (List separately in addition to
code for primary procedure)). We also believe that this procedure is being performed in numerous hospitals on an outpatient basis. Accordingly, we are removing the procedure
described by CPT code 00670 from the IPO list for CY 2019. Because this spine procedure code is an add-on code, in accordance with the regulations at
42 CFR 419.2(b)(18), under the OPPS, this procedure is packaged with the associated procedure and assigned status indicator “N” (Items and Services Packaged into APC
Rates) for CY 2019. With respect to the commenters’ recommendation that we remove CPT code 63265 (Laminectomy for excision or evacuation of intraspinal lesion other than
neoplasm, extradural; cervical), CPT code 63266 (Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; thoracic), CPT code
63267 (Laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural; lumbar), and CPT code 63268 (Laminectomy for excision or
evacuation of intraspinal lesion other than neoplasm, extradural; sacral) from the IPO list, we intend to continue to review these procedures and the appropriateness of the potential
removal from the IPO list for subsequent rulemaking. In regard to the commenters’ recommendation to remove all orthropaedic, arthroplasty, and joint replacement procedures from the IPO list, we do not believe that
we have sufficient data to support removal of all orthopaedic, arthroplasty, and joint replacement procedures from the IPO list. However, we encourage stakeholders to
submit specific procedures, along with evidence, to support their requests for removal from the IPO list. In conclusion, the complete list of procedure codes that are placed on the IPO list
for CY 2019 is included as Addendum E to this CY 2019 OPPS/ASC final rule with comment period (which is available via the Internet on the CMS website).
Table 49 below contains the final changes that we are making to the IPO list for CY 2019.
TABLE 49.—CHANGES TO THE INPATIENT ONLY LIST FOR CY 2019
CY 2019 CPT Code CY 2019 Long Descriptor Action CY 2019 OPPS APC Assignment CY 2019 OPPS Status Indicator
31241 Nasal/sinus endoscopy, surgical; with ligation of sphenopalatine artery Removed from IPO list
01402 Anesthesia for open or surgical arthroscopic procedures on knee joint; total knee arthroplasty
0266T Implantation or replacement of carotid sinus baroreflex activation device; total system (includes generator placement, unilateral or bilateral lead placement,
intra-operative interrogation, programming, and repositioning, when performed).
00670 Anesthesia for extensive spine and spinal cord procedures (eg, spinal instrumentation or vascular procedures) Removed
C9606 Percutaneous transluminal revascularization of acute total/subtotal occlusion during acute myocardial infarction, coronary artery or coronary
artery bypass graft, any combination of drug-eluting intracoronary stent, atherectomy and angioplasty, including aspiration thrombectomy when
performed, single vessel