"My group manages eight hospital labs and a physician group-owned outpatient lab that provides services in nine outpatient clinics… We are critically dependent on appropriate reimbursement for vascular ultrasound services to be able to maintain the high-quality service we provide in the community. The restructuring of these imaging APCs, which do not maintain the current level of reimbursement for complete vascular ultrasound procedures, will definitely impede our service and increase reliance on more expensive studies such as CTAs and MRAs."
– Letter to CMS from Vascular Surgeon
A swift response from the SVS Washington office and a resulting grassroots letter-writing campaign by SVS members helped win vascular surgeons members – and their patients – a major victory.
Surgeons will now receive fair reimbursement for imaging services, almost twice what had been proposed in one case, and their patients will have access to vital non-invasive ultrasound procedures.
The response, which also included working in close collaboration with the Society for Vascular Ultrasound, followed a careful reading and interpretation by the SVS Policy and Advocacy Council and consultants of the 2018 Hospital Outpatient Prospective Payment System (HOPPS) Final Rule. This rule had mistakenly reassigned several vascular ultrasound procedure codes, resulting in a reduction in reimbursement and jeopardizing access to the procedures for patient care.
Because the HOPPS rule also sets Medicare reimbursement rates for the technical component of the procedures, payments in both the hospital and office-based settings would have been affected. This would further restrict access to these vital studies that determine the risk of stroke and aortic disease, among other pathologies.
The SVS believed that the Centers for Medicare and Medicaid Services (CMS) did not realize how devastating these cuts would be for patients and that these procedure codes had been mistakenly assigned to an incorrect Ambulatory Payment Classification (APC) level for reimbursement.
The Washington office responded swiftly, organizing a grassroots effort that included personal letters from many SVS members who described the negative impact these cuts would have on their ability to provide vascular ultrasound studies to their patients.
Physician members of Congress also signed a letter to CMS and Rep. Larry Bucshon (R-IN), M.D., called Administrator Seema Verma. These activities were instrumental in CMS issuing a correction notice to its 2018 HOPPS Final Rule. It includes reassigning CPT 93880 (duplex scan of extracranial arteries; complete bilateral study) to APC 5523 (x-ray and related services, level 3) from APC 5522 (x-ray and related services, level 2), with a payment rate of $232.31 for level 3 versus $118.74 for level 2.
Two other complete vascular ultrasound procedures, CPT 93930 (duplex scan of upper extremity arteries or arterial bypass grafts) and CPT 93978 (duplex scan of aorta, inferior vena cava, iliac vasculature or bypass grafts) were also reassigned to level 3. These reassignments were effective on Jan. 1.
This CMS action, stimulated by the SVS leadership, is a major victory for vascular surgeons, who will receive fair reimbursement, and patients, who will have access to vital non-invasive ultrasound procedures.