Regulatory Affairs
FAQs about new coding and billing changes for hyperbaric oxygen therapy
Removal of C1300/emergence of G0277
Main Point: Payment methodology will be changing in hyperbaric medicine, and although the final interpretation and decision by CMS will not be published until March 2015, there are some things that can be shared with some certainty.
Answer: Yes
Code 99183 has never been valued by the American Medical Association Relative Value Update Committee (AMA RUC). It was given a value by CMS in 1994, and has remained unchanged since that time, with a work value of 2.34 RVUs (relative value units). This year, due to increased utilization (many more hyperbaric treatments being billed), 99183 was selected for review. The process of valuing a code includes a physician survey, a defining of the practice expense, and then a presentation in front of the RUC defending the request for keeping the value unchanged. The typical code that comes up for review is decreased about 20%. After much debate, the RVUs were determined to be 2.11. This represents approximately a 9% decrease in the payment for hyperbaric chamber supervision.
The reimbursement for physicians is comprised of three elements, work, indirect practice expense, and malpractice. When combined, the total RVUs for a facility based provider will be 3.13 RVUs. Those RVUs, multiplied by the conversion factor (CF) and your Geographic Price Index will give you the final amount. Nationally it should be in the range of $112.06. Currently the total RVUs for 99183 in a facility setting is 3.45 (CF $35.8228) for a national payment of $123.59.
Answer: ONE
Physicians, or other qualified healthcare providers, will continue to bill for this professional service on a per session/treatment basis. FOR THE SUPERVSION OF HYPERBARIC OXYGEN THERAPY, PRACTITIONERS WILL CONTINUE TO BILL ONE (1) CODE 99183 FOR EACH HYPERBARIC OXYGEN THERAPY TREATMENT.
Answer: This code will be deleted.
C1300, Hyperbaric oxygen under pressure, full body chamber, per 30 minute interval will be deleted.
Answer: G0277
In place of C1300, a new code was created, G0277. It will have exactly the same description as C1300, but will not be limited to outpatient hospital sites of service (OPPS).
As part of the AMA RUC process, the evaluation of 99183 resulted in a review of the DIRECT practice expense that is incurred by physicians providing hyperbaric oxygen therapy in a non-hospital based setting. The last time this was addressed was in 2004/2005 by CMS, and the inputs were not validated by the AMA RUC process. In that assessment, the value of oxygen for an ENTIRE monoplace hyperbaric oxygen treatment was $0.54. Air utilization was valued at $4.68 for air breaks. After rigorous debate at the AMA RUC meeting, revised direct practice expense inputs were recommended.
Interested stakeholders had been meeting with CMS to discuss the issue of physician supervision and the inequality of “practice expense” when compared to hospital based reimbursement. When CMS looked at the RUC recommendation, and took stakeholders comments concerning the discrepancy into consideration, they chose to create a code, G0277, which can be billed across all places of service.
Answer: Currently, the OPPS APC code 0659 / G0277 will be paid at about $109.24 for a 30 minute segment. When billed at a place of service non-facility, the RVU value will be 1.32 x CF ($35.8013)/ 30 minutes.
CMS posted the first version of the Final rule with a comment period on physician reimbursement on October 31, 2014. The comment period ends December 30, 2014, and CMS will most likely release the final version with changes in March 2015.
The Final Rule for OPPS is at:
http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HospitalOutpatientPPS/Hospital-Outpatient-Regulations-and-Notices-Items/CMS-1613-FC.html
The Final Rule for physicians is at:
http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/PFS-Federal-Regulation-Notices-Items/CMS-1612-FC.html
http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2015_Medicare_Physician_Fee_Schedule_Final_Rule.pdf
The AMA has a large section that describes in detail all the relevant issues. The CF is based on a calculation that is influenced by the Sustainable Growth Rate. This is the “doctor fix” that keeps getting raised in Congress.
http://www.ama-assn.org/ama/pub/physician-resources/solutions-managing-your-practice/coding-billing-insurance/medicare/the-medicare-physician-payment-schedule.page?