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Vascular Embolization reimbursement recoupment

Posted By Naveen K. Atray, Monday, January 23, 2017
Updated: Monday, January 23, 2017

We recently received a notification from our CMS intermediary (Noridian) that they will initiate recoupment proceedings going all the way back to 2014 for the use of CPT 37241 (Vascualr Embolization or occlusion).

The letter states our use of 37241 does not reflect vascular embolization or occlusion as defined by AMA (congenital or acquired venous malformations, varices, varicocele, venous/capillary hemangiomas).

 

I wonder if anyone else is in receipt of this letter. The use of this code seems perfectly in line with RPA/ASDIN Coding manual. I would be curious as to  how ASDIN coding committee would respond to it? 

Thanks.

 

Naveen Atray 

Sacramento, CA

 

 

Tags:  accessory veins/ Coils 

Permalink | Comments (15)
 

Comments on this post...

...
Eric Ladenheim says...
Posted Monday, January 23, 2017
I got hurt as well by the mass recoupment of 37241. It will very negatively affect our 1st quarter cash flow. They made it very clear that they intend to recoup all uses of the code in place of service 11.
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Timothy A. Pflederer says...
Posted Monday, January 23, 2017
All,
CPT 2016 introductory section pages 231 - 233 make it completely clear that 37241 is the correct code for embolization of accessory veins in a dialysis fistula. Noridian is not correct and you should appeal this. see relevant section copied:

The work of catheterizing all the veins in the dialysis AV
shunt is included in 36147 (and, if appropriate, 36148).
Selective catheterization of the inferior/superior vena cava
and central veins cannot be separately reported when
performed from a direct puncture of the AVF/AVG.
However, if additional venous side branches off of the
conduit, known as accessory veins, are separately
catheterized for diagnosis or intervention such as
embolization of a large competing accessory vein, this
additional work may be separately reported using the
appropriate selective venous catheterization codes (36011
and 36012). The embolization may be reported using
37241 once, irrespective of the number of branches
embolized.
Permalink to this Comment }

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William D. Yu says...
Posted Tuesday, January 24, 2017
For this situation, I have heard from my IR colleagues that the code they are using is 36909. Any insights?
Permalink to this Comment }

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Gerald A. Beathard says...
Posted Tuesday, January 24, 2017
+36909 is the correct code starting in 2017,
It did not exist until this year
Permalink to this Comment }

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Ryan D. Evans says...
Posted Tuesday, January 24, 2017
Sorry to go off on a tangent, but I have a question about the +36909 add on code mentioned above. Does anyone know of the 36907-9 add on codes will be reimbursed for a FACILITY fee at an ASC. The CMS 2017 final rule fee schedule for ASC site of service doesn't have a value for any of these 3 codes. Could it be that they will only be paid in an EOP?
Permalink to this Comment }

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Eric Ladenheim says...
Posted Tuesday, January 24, 2017
No. Add on codes historically have never been separately paid to the facility in the ASC setting
Permalink to this Comment }

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Joseph G. Abdallah says...
Posted Tuesday, January 24, 2017
has anyone billed so far any of the add-on codes in an ASC. Would you share the reimbursement rate.
I agree with Ryan that does not seem there is a facility fee for +36907-9.
Permalink to this Comment }

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Gerald A. Beathard says...
Posted Tuesday, January 24, 2017
add on codes are not on the approved list for ASCs
they can not be billed
Permalink to this Comment }

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Wissam Saliba says...
Posted Tuesday, January 24, 2017
Dr Bethard, are you saying that in ASC if you do a fistulogram and central angioplasty or central stent placement, you cannot bill for anything but the angiogram alone?
Permalink to this Comment }

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Gerald A. Beathard says...
Posted Tuesday, January 24, 2017
That is correct if it's an ASC
Permalink to this Comment }

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Ryan D. Evans says...
Posted Tuesday, January 24, 2017
It doesn't seem logic that if you did a dialysis access angiogram and ONLY a central pta (no pta within the dialysis conduit) that you could only bill a 36901 in an ASC setting. My intuition would suggest you could bill the angioplasty code 36902. However, I may be presenting "alternative facts" as I have no basis for this assumption.
Permalink to this Comment }

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Timothy A. Pflederer says...
Posted Wednesday, January 25, 2017
Ryan,
Unfortunately you have to follow the CPT descriptors. 36902 is specific to the peripheral segment of the dialysis access so cannot be used for the central segment (central veins)
Permalink to this Comment }

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Ryan D. Evans says...
Posted Wednesday, January 25, 2017
Thank you for clarification. Looks like a CMS oversight in the new bundling. Hopefully they will correct this next year. ASCs will need to send central lesions to the hospital. Unless of course there is a peripheral lesion also. The $300-400 for angiogram is not going to cover the use of the facility or supplies for a central PTA. Reminds me of the old days when we had to send stents to the hospital.
Permalink to this Comment }

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Gerald A. Beathard says...
Posted Wednesday, January 25, 2017
I don't think this is going to be corrected at least not anytime soon. It's not just the dialysis access add on codes, it is all add-on codes across the board. Apparently it has been this way ASCs for some time
Permalink to this Comment }

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Ryan D. Evans says...
Posted Wednesday, January 25, 2017
I guess the biggest loss would be central stenting in an ASC, which would also just get paid at the just the angiogram rate of $300-400, when the stent cost is $2000-3000.

Last year I was able to bill 35476 for a central angiogram or 37238 for a central stent in an ASC setting. Why would the ability to do these procedures in an ASC suddenly not be reimbursed? It doesn't make sense that CMS would be trying to move these procedures out of an ASC and into the office setting. Maybe they weren't thinking of the possibility that a central lesion could exist without coexistence of a dialysis access lesion.

I'm not sure how many ASDIN members are working out of an ASC, probably this number will increase with changes in billing, but it might be something worthwhile for ASDIN to write a comment letter to CMS.

I can already predict the negative modeling of physician behavior due to this lack of an appropriate (non-add on) cpt code for central work. Physicians will be either sending patients to the hospital or needlessly cannulating an Axillary or femoral (non dialysis access site) vein for central pta and stenting.
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