LCD draft for Cardiac Rehab effective 2/5/2019

Have you seen the recent draft of the Cardiac Rehab LCD?

LCD for cardiac rehab effective 2-2019

Reversing the Cardiac Effects of Sedentary Aging in Middle Age—A Randomized Controlled Trial Implications For Heart Failure Prevention

https://www.ahajournals.org/doi/abs/10.1161/CIRCULATIONAHA.117.030617?fbclid=IwAR3xEfFwooltAReCbjRkXdGv56wgFHtKtduD1IWyGB-YQExq-cCGmrp3m8M

Coastal Regional Meeting

We had a great meeting for the Coastal Region on Friday, October 19th.  Attached are some of the power point presentations from that meeting.

AACVPR – National Conference Update 2018
Pulmonary

 

Million Hearts Initiative

AACVPR has teamed up with the CDC and Million Hearts to focus on increasing cardiac rehab referral and participation by eligible patients.  They have developed some wonderful tools that all of us can use.  Check it out!

https://millionhearts.hhs.gov/tools-protocols/tools/cardiac-rehabilitation.html

Reimbursement information

Just a few pieces of information that you might find helpful:

As you may be aware Palmetto released a Draft LCD for Supervised Exercise training.  Both the NCCRA and AACVPR MAC committee gave input on this draft but the future LCD is now available for your review:  https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=37774&ContrId=381&ver=4&ContrVer=1&CntrctrSelected=381*1&Cntrctr=381&name=&DocType=Future%7cAllProposed&s=34%7c48%7c53%7c58&bc=AAAAAAQAAAAA&
It is effective for services performed on or after 11/19/2018.

The Office of the Inspector General  (OIG) recently examined appeals and denials of Medicare Advantage  and found that MAOs overturned 75% of their own denials during 2014-2016. Furthermore, independent reviewers at higher levels of the appeals process overturned additional denials in favor of beneficiaries and providers.   This is highly unusual because beneficiaries and providers rarely use the appeals process, which is designed to ensure access to care and payment. The report recommends that CMS (1) enhance its oversight of MAO contracts including those with extremely high overturn rates and/or low appeal rates and take corrective action as appropriate; (2) address persistent problems related to inappropriate denials and insufficient denial letters in Medicare Advantage; and (3) provide beneficiaries with clear, easily accessible information about serious violations by MAOs. CMS concurred with all three recommendations.  For more information you can go to http://oig.hhs.gov/oei/reports/oei-09-16-00410.asp

Cardiac and Pulmonary rehab also remains on the OIG work plan.  Previous OIG work identified outpatient cardiac and pulmonary rehabilitation service claims that did not comply with Federal requirements. They will assess whether Medicare payments for outpatient cardiac and pulmonary rehabilitation services were allowable in accordance with Medicare requirements. They will also determine whether potential risks in outpatient cardiac and pulmonary rehabilitation programs continue to exist.  https://oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000292.asp

If you are not familiar with the previous OIG work here is the report:  OIG audit of Englewood hosp

 

 

 

Piedmont Region Fall Meeting

Thank you to everyone that came out to the Piedmont Region Fall Meeting.  Here are the slides for those that weren’t able to attend:

2018 Introduction
Cardiac Rehabilitation – Jan Wagoner and John Pasquini
PAD – Carl King
Pulmonary CSI – Kim Clark

Mountain Region Meeting

Thank you to all those who made it out to the Mountain region meeting!  We had a great turn out.  Here are the slides for those who were not able to get away to the meeting.

ATRIUM-clinical considerations for OHT and VAD
Unlocking the Secrets Presentation

Legislative/Reimbursement Updates

SET Draft LCD

As you know Palmetto released a draft LCD for Supervised Exercise training on May 17th.  The comment period ran through July 19th and we are now waiting on their final decision.  Responses were provided to Palmetto from many organizations and groups including NCCRA and AACVPR.  We will communicate the final LCD as soon as we know it’s available.

Response to SET draft LCD

Section 603 of BBA of 2015 – impacting movement to off campus locations

Section 603 of the Balanced Budget Act of 2015 mandated that hospitals would no longer be able to bill under the hospital outpatient methodology, i.e., higher reimbursement rate, under certain conditions:

  1. If an existing off campus (beyond 250 yards) service moves to a new location, the hospital is required to bill at the physician fee schedule rate rather than the hospital outpatient rate.
  2. If a hospital opens a NEW hospital outpatient service, that new service must be within 250 yards of the main campus in order to receive hospital outpatient reimbursement; otherwise, the physician fee schedule rate applies.

Impact on Pulmonary/Cardiac Rehabilitation (PR/CR): Hospitals that choose to expand or relocate (beyond the 250 yard threshold) services must bill at the physician fee schedule rate, thereby creating a very strong disincentive for hospitals to improve access to PR/CR services. (A very limited number of exceptions to this exist.)  CMS recognizes this reality as an “unintended consequence” of Section 603, but the Agency states it has no authority to address our problem.

Political considerations: Section 603 received strong support on Capitol Hill, on both sides of the political aisle as it addressed an important issue at one end of the Medicare scale. However, PR/CR are at the other end of the scale, definitively evidenced by Medicare data.

  • Pulmonary rehabilitation billing under the physician fee schedule for all medical specialties for G0424 totaled $535K in 2014, a 22% reduction from 2012. The largest single specialty, pulmonary disease, is under $230K for G0424.
  • Cardiac rehabilitation billing under the physician fee schedule for all medical specialties for CPT 93798 totaled $1.2M in 2014, a 30% reduction from 2012. The largest single specialty, cardiology, is under $1M for 93798.

This clearly documents that that the primary premise of Section 603 does not apply to either PR or CR because hospitals are not purchasing pulmonary or cardiac practices to benefit from the higher reimbursement rate for PR/CR services. Simply stated, these services are NOT being performed in physician offices, nor have they been provided in that setting for years.

Solution: We are seeking sponsors for legislation that would exempt hospitals from Section 603 and the implementing regulations by creating specific thresholds. As long as no physician specialty, nationwide, bills for any CPT or HCPCS code under the Medicare Physician Fee Schedule in an aggregate amount greater than $1million in the previous year for which data are available, that code (or codes) would be exempt from Section 603 requirements.

As noted above, because billing for 93798 and G0424 under the physician fee schedule has no physician specialty billing exceeding $1M, those codes would be exempt from Section 603 requirements.

NCCRA representatives recently met with Representative Butterfield with the hope of gaining his support in introducing legislation that would help this issue.  Although he was able to provide some advice and direction, he has not committed to assisting with this effort at this time.  We appreciate the assistance we received from the programs in his district that wrote letters of support for this work.   AACVPR will hopefully be able to partner with other House and Senate members to get this bill created and moved forward.

 

Mark Your Calendars for Upcoming Regional meetings

We know how quickly your calendars fill up so please make note of the following upcoming meetings:

Go to http://nccraonline.org/events/ for more information on all of these events.

Mountain Region Fall symposium
October 1 from 8:30-1:00pm
For more information please contact Jennifer (Jennifer.Simmons@iredellhealth.org)

Piedmont Region Meeting
October 5 from 9am to 2pm
For more information please contact Hannah Wofford (hannahewofford@gmail.com)

Coastal Region Meeting
October 19th
For more information please contact Kelly Forrest (KForrest@carolinaeasthealth.com)

 

 

 

Program Updates on the Website

Please make sure that you have a representative from your program review the information on the website.  Let us know if there have been any changes to contact information, location, or contact person.  We have also had a recent request to include fax numbers if possible.  Thank you!!