2022 CMS Proposed Rule Summary

2022 CMS Proposed Rule Summary, Anesthesia
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By: Hal Nelson, CANPC
MSN Vice President, Anesthesiology Services

Medicare Physician Fee Schedule

The conversion factor used for medical/surgical services (line, blocks, etc.) decreased from $34.89 to $33.58 (-3.8%). The national anesthesia conversion factor decreased from $21.56 to $21.04 (-2.5%).

Base Unit Increase

CMS proposed increasing the base unit value for code 00537 (Anesthesia for Cardiac Electrophysiologic Procedures) from 7 to 10, consistent with the current ASA value.

Evaluation & Management Visits

CMS proposed to refine policies for split (shared) E/M visits to:

  •  better reflect current practice
  • recognize the evolving role of non-physician practitioners
  • clarify the conditions of payment that must be met in order to be paid.

A split (shared) E/M visit is defined as an E/M visit that is provided in a facility setting by a physician & a NPP in the same group. The provider who provides the substantive portion of the visit (more than half the total time spent) would bill for the visit and this provider must sign & date the medical record.

Billing for PAs

CMS proposed implementing section 403 of the Consolidated Appropriations Act of 2021, which authorizes Medicare to make direct payment to PAs for professional services they furnish under Part B, beginning January 1, 2022.

Currently, Medicare can only make payment to the employer of a PA. Consequently, PAs cannot bill & be paid directly by the Medicare program for their professional services. They also do not have the option to reassign payment for their services or to incorporate with other PAs to bill the program for their services.

Beginning January 1, 2022, PAs would be able to bill Medicare directly for their services and to reassign payment for their services.

New codes for Anesthesia Services of Image-Guided Spinal Procedures

CMS proposed creating more granular codes to represent the above-mentioned procedures. These 6 codes would be used in place of current code 01936 (5 base units), and are listed below:

  • 01XX2 (Anesthesia for percutaneous image-guided injection, drainage or aspiration procedures on the spine or spinal cord; cervical or thoracic) 4 base units

  • 01XX3 (Anesthesia for percutaneous image guided injection, drainage or aspiration procedures on the spine or spinal cord; lumbar or sacral) 4 base units

  • 01XX4 (Anesthesia for percutaneous image guided destruction procedures by neurolytic agent on the spine or spinal cord; cervical or thoracic) 4 base units

  • 01XX5 (Anesthesia for percutaneous image guided destruction procedures by neurolytic agent on the spine or spinal cord; lumbar or sacral) 4 base units

  • 01XX6 (Anesthesia for percutaneous image guided neuromodulation or intravertebral procedures (eg. Kyphoplasty, vertebroplasty) on the spine or spinal cord; cervical or thoracic) 5 base units

  • 01XX7 (Anesthesia for percutaneous image guided neuromodulation or intravertebral procedures (eg. Kyphoplasty, vertebroplasty) on the spine or spinal cord; lumbar or sacral) 5 base units

Reduced beneficiary co-insurance for screening colonoscopies converted to diagnostic/therapeutic procedures

To address patient concerns over out of pocket costs for screening colonoscopies converted to polypectomies, CMS proposed the following tiered approach:

  • CY 2022 – 80% Medicare coverage, 20% Patient coinsurance
  • CY 2023-2026 – 85% Medicare coverage, 15% Patient coinsurance
  • CY 2027-2029 – 90% Medicare coverage, 10% Patient coinsurance
  • CY 2030 and beyond – 100% Medicare coverage, 0% Patient coinsurance

Medicare currently pays 100% for screening colonoscopies, but only pays 80% if a polypectomy is subsequently performed during the same operative session.

MIP Value Pathways (MVPs)

7 MVPs were proposed for 2023 and CMS is seeking comment on removing “traditional” MIPS at the end of the 2027 performance/data submission periods.

Proposed MVP Clinical areas for 2023:

  • Rheumatology

  • Stroke care & prevention

  • Heart disease

  • Chronic disease management

  • Lower extremity joint repair (e.g., knee replacement)

  • Emergency medicine

  • Anesthesia

Changes to CMS Inpatient Only (IPO) List

The 2022 OPPS/ASC Proposed Rule lists the following 24 anesthesia codes as being payable in inpatient hospital settings only.

Should CMS finalize this rule for next year, it will create a change in venue for such procedures, as surgeons will be forced to perform these cases in inpatient hospital settings only, and not ASCs. MSN Healthcare Solutions is keeping a close eye on the situation and will provide updates, as they become available. 

CPT Code/Description

 

  • 00192 Anesthesia for procedures on facial bones or skull; radical surgery (including prognathism)

  • 00474 Anesthesia for partial rib resection; radical procedures (e.g., pectus excavatum)

  • 00604 Anesthesia for procedures on cervical spine and cord; procedures with patient in the sitting position

  • 00904 Anesthesia for; radical perineal procedure

  • 0095T Removal of total disc arthroplasty (artificial disc), anterior approach, each additional interspace, cervical

  • 0098T Revision including replacement of total disc arthroplasty (artificial disc), anterior approach, each additional interspace, cervical

  • 01140 Anesthesia for interpelviabdominal (hindquarter) amputation

  • 01150 Anesthesia for radical procedures for tumor of pelvis, except hindquarter amputation

  • 01212 Anesthesia for open procedures involving hip joint; hip disarticulation

  • 01232 Anesthesia for open procedures involving upper two thirds of femur; amputation

  • 01234 Anesthesia for open procedures involving upper two thirds of femur; radical resection

  • 01274 Anesthesia for procedures involving arteries of upper leg, including bypass graft; femoral artery embolectomy

  • 01404 Anesthesia for open or surgical arthroscopic procedures on knee joint; disarticulation at knee

  • 01486 Anesthesia for open procedures on bones of lower leg, ankle, and foot; total ankle replacement

  • 0163T Total disc arthroplasty (artificial disc), anterior approach, including discectomy to prepare interspace (other than for decompression)

  • 01634 Anesthesia for open or surgical arthroscopic procedures on humeral head and neck, sternoclavicular joint, acromioclavicular joint, and shoulder joint; shoulder disarticulation

  • 01636 Anesthesia for open or surgical arthroscopic procedures on humeral head and neck, sternoclavicular joint, acromioclavicular joint, and shoulder joint; interthoracoscapular (forequarter) amputation

  • 01638 Anesthesia for open or surgical arthroscopic procedures on humeral head and neck, sternoclavicular joint, acromioclavicular joint, and shoulder joint; total shoulder replacement

  • 0164T Removal of total disc arthroplasty, (artificial disc), anterior approach, each additional interspace, lumbar

  • 0165T Revision including replacement of total disc arthroplasty (artificial disc), anterior approach

  • 01756 Anesthesia for open or surgical arthroscopic procedures of the elbow; radical procedures

  • 0202T Posterior vertebral joint(s) arthroplasty (for example, facet joint[s] replacement) including facetectomy, laminectomy, foraminotomy, and vertebral column fixation, injection of bone cement, when performed, including fluoroscopy, single level, lumbar spine

  • 0219T Placement of a posterior intrafacet implant(s), unilateral or bilateral, including imaging and placement of bone graft(s) or synthetic device(s), single level; cervical

  • 0220T Placement of a posterior intrafacet implant(s), unilateral or bilateral, including imaging and placement of bone graft(s) or synthetic device(s), single level; thoracic
Hal Nelson, Vice President Anesthesiology Services

 

Hal Nelson, CANPC
has 30 years experience on both the payer and RCM side, with a focus in Anesthesia. He formerly worked as a senior claims approver at United Healthcare, as well as a compliance officer for multiple national billing companies. He has also taught the CPC coding curriculum collegiately in Atlanta. His broad based experience ensures that MSN clients will have a resource for documentation and billing issues. His past speaking engagements include ASA, MGMA, Dartmouth, and Johns Hopkins. 

This educational guide was prepared as a tool to provide education for documentation and coding. It is not intended to affect clinical treatment patterns. The material provided is for informational purposes only. Efforts have been made to ensure the information within this document was accurate on the date of distribution. Reimbursement policies vary from insurer to insurer and the policies of the same payer may vary within different U.S. regions. All policies should be verified to ensure compliance. CPT® codes, descriptions and other data are copyright of the American Medical Association (or such other date of publication of CPT®).All Rights Reserved. CPT® is a registered trademark of the American Medical Association. Proprietary and confidential document.  All rights reserved. No part of this document may be reproduced or used in any manner without the written permission of MSN Healthcare Solutions, LLC.