Payment Rules For Interventional Pain Physicians In Office, ASC, And HOPD Settings

CMS RELEASES 3 PAYMENT RULES FOR 2020: DRASTIC CUTS FOR SUPERION, DISC DECOMPRESSION; INCREASES FOR IMPLANTABLES; AND RELEASE OF NEW CODES FOR GENICULAR AND SACROILIAC JOINT NERVE BLOCKS

The following is important information on the newly released 2020 payment rules. ASIPP and SIPMS will be sending comment letters to CMS in the near future. You may also send comment letters to them on these payment rules. 

The Centers for Medicare & Medicaid Services (CMS) released three proposed rules on July 29, which include:

1.         Payments for physician services and expanded price transparency initiatives
2.         Hospital outpatient department payments
3.         Ambulatory surgery center payments

INTERVENTIONAL SPECIFIC NEWS

There is some good news, some bad news, and some ugly news. Let us go from worst to the best:

UGLY NEWS

Physician Payment Schedule

1. Multiple intercostal nerve blocks see reductions of 78.2% for physicians in non-facility (office) and 72.3% in a facility setting (ASC or HOPD).
2. Vagus nerve block and pudendal nerve block will see cuts of 41.7% for non-facility and 49.5% for facility.
3. Ilioinguinal hypogastric non-facility reductions are 18.7% and for facility they are 41.1%.
4. Multiple codes including trigeminal nerve block, greater occipital nerve block, suprascapular nerve block, intercostal nerve block will see cuts of 10% -25%. For facility, these cuts are even higher than non-facility.
5.Electronic analysis of programmable pump (CPT codes 62397 & 62368): 19.2% decrease in office-settings
.


Hospital Outpatient Department

1. Interspinous prosthesis (Superion) faces major cuts with 22.3% in a hospital outpatient setting from $15,402.50 to $11,960.30
2. Disc decompression faces substantial cuts of 61.7% from $4,566.10 to $1,747.30.


Ambulatory Surgery Centers

 ASCs are paid less than 50% of hospital outpatient departments for non-implantables.

1. Interspinous prosthesis, or Superion, faces 22.4% cut compared to 2019 from $12,596.88 to $9,779.68.
2. Trigeminal nerve block, greater occipital nerve block, vagus nerve block, and suprascapular nerve block face cuts as high as 38.2%.

BAD NEWS

Physician Payment Schedule
Physician payments are reduced in multiple categories as high as 10%, mostly less than 5%, in addition to drastic cuts as shown above.

GOOD NEWS

Some of the good news include increase in payments and new codes for genicular nerves, sacroiliac joint nerve blocks, and denervation; however, the prices seem to be preliminary, so probably these will be adjusted in the final rule.

Physician Payment Schedule

  • Physicians may see significant increases of 17.6% for non-facility setting for implantation of neuroelectrodes increasing from $1,657.08 to $1,948.84.
  • Physicians will also see significant increase for destruction by neurolytic agent of other peripheral nerve or branch of 82.6% in non-facility setting, and 26.2% in facility setting, increasing from $139.11 to $254.07 and $96.95 to $122.34.
  • Genicular nerve blocks for office setting are $85.89 for facility and $217.98 for non-facility.
  • Genicular nerve radiofrequency for facility is $152.30, whereas for non-facility it is $347.90.

    • Sacroiliac joint injection: $86.98 for facility, whereas for non-facility it is $224.48
    • Sacroiliac joint nerve blocks: $81.92 for facility, whereas for non-facility it is $217.98

      Sacroiliac joint nerve neurotomy: $200.30 for facility, whereas for non-facility it is $440.29

      Hospital Outpatient Department

      Under the HOPD payments, while hospitals continue to receive double the ASC payments for non-implantables and triple the office payments, they are not really facing any major cuts other than the ones described above

      1.         Significant increases seen for tunneling of epidural catheter with 23.8% from $4,566.10 to $5,652.90.

      2.         Removal of the spine infusion device shows 23.8% increase from $4,566.10 to $5,652.90.

      3.         Removal of spine electrode plate increases 13.5% from $2,879.80 to $3,269.90.

      4.         Revision removal of neuroreceiver also shows 13.5% increase from $2,879.80 to $3,269.90

      5.         Genicular nerve block $627.4

                  Genicular nerve neurotomy $808.6

      6.         Sacroiliac joint intraarticular injection $ 627.4

      Sacroiliac joint nerve blocks $ 627.4

      Sacroiliac joint nerve neurotomy $ 1,747.3

      Ambulatory Surgery Centers

                ASCs are reimbursed at less than 50% of hospital outpatient departments for non-implantables.


      1.         Tunneled intrathecal or epidural catheter will see 22.9% increase from $2,480.08 to $3,049.13.

      2.         Implantation or replacement of non-programmable pump will see 12.3% increase from $12,911.04 to $14,503.23.

      3.         Removal of spine infusion device is increased 15.7% from $1,919.87 to $2,220.59.

      4.         Removal of spine electrode plate and revision/removal of the neuro-receiver sees 29.4% increase from $1,482.75 to $1,918.97.

      5.         Genicular nerve blocks $156.99

                  Genicular nerve neurotomy $ 249.38

      6.         Sacroiliac joint intraarticular injection $ 311.57

      Sacroiliac joint nerve blocks $ 311.57

      Sacroiliac joint nerve neurotomy $ 792.67

      Please see the proposed payment rates for IPM codes.


      Physician Payment Schedule: https://www.asipp.org/Fee%20Schedules/2020%20Physician%20Proposed%20Fee%20Schedule.pdf

      Ambulatory Surgery Center: https://www.asipp.org/Fee%20Schedules/2020%20ASC%20Proposed%20Fee%20Schedule.pdf

      Hospital Outpatient Department: https://www.asipp.org/Fee%20Schedules/2020%20HOPD%20Proposed%20Fee%20Schedule.pdf

       

      PAYMENT UPDATES

      1. CMS proposed increasing the outpatient department payment rates by 2.7% in 2020 compared to 2019. The agency estimated that total payments to hospital outpatient services providers will be roughly $6 billion higher in 2020 than 2019.

      2. If the budget neutrality adjustment is to account for changes in relative value units (RVUs), as required by law, the proposed 2020 conversion factor is $36.0896, a slight increase above the 2019 conversion factor $36.0391.


      Site-Neutral Payments

      The proposed rule would finish phasing in a policy adapted last year to make payments for clinic visits site-neutral by reducing the payment rate for hospital outpatient clinics to 40% of the Outpatient Prospective Payment System (OPPS) rate.

      Price Transparency

      The proposed rule defines standard changes, to include hospitals’ gross charges and payer-specific negotiated rates for an item or service.

      Telehealth Services

      CMS proposes to add an additional set of codes for Telehealth evaluation and management coding and update. Separate rates would be set for all five levels of coding for evaluation and management visits for established patients. However, Level 5 code will be removed for new patient evaluations in an office setting.

      Merit-based Incentive Payment System (MIPS)

      MIPS appears to be dwindling down with 1.4% updates per year compared to previously promised 9-13% updates.

      Please see the proposed payment rates for IPM codes.


      Physician Payment Schedule: https://www.asipp.org/Fee%20Schedules/2020%20Physician%20Proposed%20Fee%20Schedule.pdf

      Ambulatory Surgery Center: https://www.asipp.org/Fee%20Schedules/2020%20ASC%20Proposed%20Fee%20Schedule.pdf

      Hospital Outpatient Department: https://www.asipp.org/Fee%20Schedules/2020%20HOPD%20Proposed%20Fee%20Schedule.pdf