Re: CMS-1631-FC Medicare Program; Payment Policies Under the Medicare Physician
Fee Schedule (MPFS) and Other Revisions to Part B for CY 2016 Final Rule
Dear Mr. Slavitt:
On behalf the American Association of Neurological Surgeons (AANS), the American College of
Radiology (ACR), the American Society of Neuroradiology (ASNR), the Congress of Neurological
Surgeons (CNS), the Society of Interventional Radiology (SIR), the Society of Neurointerventional
Surgery (SNIS), and the Society of Vascular and Interventional Neurology (SVIN), we appreciate the
opportunity to comment on an important payment provision in the above referenced Centers for Medicare
and Medicaid Services’ (CMS) 2016 Medicare Physician Fee Schedule (MPFS) Final Rule. For the
reasons described below, we disagree with the CMS proposal regarding valuation for Intracranial
Endovascular Intervention procedures reported with new CPT codes 61645, 61650, and 61651 and
believe they are based on fundamentally inaccurate assumptions.
Summary
Inaccuracies in CMS Interim Final RVUs for Intracranial Endovascular Intervention Codes
- CMS has stated that the services now reported with the three new CPT codes 61645, 61650, and 61651 were previously reported using CPT codes 61640-61642 (Balloon dilatation of intracranial vasospasm). This is incorrect. The codes were previously reported with CPT code 37184 (66% Inpatient Hospital), 36224 (58% Inpatient Hospital) and 36228 (84% Inpatient Hospital) according to 2014 Medicare claims data—all predominately inpatient.
- CMS has stated that CPT codes 61645, 61650, and 61651 would be performed in the outpatient setting. However, these procedures are for acute stroke patients who require constant neurologic monitoring in a dedicated stroke unit or in an intensive care unit for at least several days.
- CMS has changed the RUC recommended crosswalk for the malpractice relative values for these codes based on an incorrect assumption regarding the specialty mix most likely to perform the procedures. These procedures will be performed primarily by neurosurgeons and the malpractice crosswalk used should reflect this fact.
- CMS has listed the global period for CPT code 61650 as ZZZ but this is incorrect and should be a zero day global period. CPT code 61650, is a base code and not an add-on service, making a ZZZ global designation incorrect.
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