CMS Publishes 2013 Physician Regulations: CRNAs, Fluoroscopy, Neurostimulators

On November 1, 2012, the Centers for Medicare and Medicaid Services (CMS) published a Final Rule on Medicare Physician Fee Schedule for 2013. Contained in the rule are several issues of great importance to ISIS members:

CRNAs to be paid the same as Physicians for Chronic Pain Services

In a move decried by all physician organizations, CMS reaffirmed their decision to pay CRNAs on the same level as physicians for any chronic pain management services, that they are allowed to perform by their State. ISIS submitted a letter strongly opposing the proposal (click here to review ISIS letter) and encouraged members to submit comments to CMS through provided website links and information. This decision will go into effect as of January 2013.

Members are encouraged to contact their House and Senate representatives to ask them to oppose the CMS decision and take legislative action to rescind the new rule.

Reimbursement for Fluoroscopy Guidance Code (CPT 77003)

Previously, CMS requested a review of code 77003 (Fluoroscopic guidance and localization of needle or catheter tip for spine or paraspinous diagnostic or therapeutic injection procedures (epidural or subarachnoid) due to the fact that the code was flagged as one with high expenditure. ISIS twice conducted a survey of physician work, in which multiple other physician organizations participated. The results were presented to the AMA Relative Value Update Committee (RUC) and the RUC made a recommendation to CMS that the current value should be maintained.In the rule, CMS decided to accept the RUC recommended value but on interim basis only, and is asking for another review of this code, this time along with CPT codes 77002 and 77001 (non-spine fluoroscopy guidance codes).

Reimbursement for Electrode Implantation to be Reviewed

CMS requested a review of work and practice expense values for 63650 (Percutaneous implantation of neurostimulator electrode array, epidural); ISIS submitted public comments to CMS, indicating that the review of physician work values for this code is not necessary, as it was recently reviewed; and only practice expense inputs should be assigned, since they currently do not exist in non-facility setting. In the final rule CMS appears to be agreeable to the plan that RUC will review the practice expense only, for non-facility setting. ISIS will be participating in the preparation and presentation of the proper inputs to assure fair reimbursement.