December, 2011

The AAP has issued an important call to action for pediatricians, and those who work for them, relating to a proposed change to the 96110 CPT code, a subject about which I've written many times (these are just a fraction of the blog entries, you can see them all here).

It appears that during the annual CPT review process, someone had the bright idea of changing the definition of the 96110 so that it no longer represents a crucial piece of work - something mandated by Bright Futures, in fact - and, therefore, no longer has RVUs.  Which decimates, in the true sense of the word, well visit reimbursement for physicians.

The AAP is organizing a response to CMS.  Please take the 60 seconds to participate and respond below.  It's easy and it will work if everyone pitches in.

Here's an abbreviated copy of the AAP letter:

We write to you today with a unique and urgent advocacy request due to a change in CPT code 96110, a code used to bill for essential developmental, behavioral and psychosocial screenings and services.

The U.S. Centers for Medicare and Medicaid Services (CMS) has issued a Final Rule to stop covering services associated with 96110.

Services associated with that code have become ineligible for payment within Medicare. This coding change was included in an annual review of all codes published by CMS.

Since Medicaid and private pay systems often depend on Medicare payment rules, CMS’ decision impacts children enrolled in Medicaid and in private health insurance plans.

Today, AAP president Robert W. Block, MD, FAAP, sent a letter on behalf of the Academy to CMS expressing concern with the agency’s decision and urging CMS to reinstate coverage of code 96110, among other requests. The specific portion of Dr. Block’s letter pertaining to this code is published at the bottom of this message.

Individuals can submit public comments to an online docket in response to CMS’ Final Rule. The AAP is urging its members to submit public comments between now and the deadline of Jan. 3, 2012 to urge CMS to reinstate payment for code 96110.

To submit a comment, visit the docket website and go to the upper right-hand corner to click “Submit a Comment.” You can either paste text directly into the online form or attach a separate letter with your feedback. For further guidance on how to submit comments in hard copy, please read these instructions.

Because you are submitting the comment as an individual pediatrician, you do not need to identify your AAP affiliation in the online form.

Some suggested text:

As a pediatrician, I am writing to express my concern with CMS’ recent decision to change the status of CPT code 96110, rendering the code ineligible for reimbursement under Medicare. Since Medicare payment rules often influence Medicaid and private payments, and since more than half of all Medicaid recipients are children, this decision could adversely impact children covered by Medicaid and private insurance. Please reverse this decision and reinstate coverage of services associated with code 96110. [INSERT PERSONALIZED MESSAGE: This regulatory action by CMS will directly impact my patients by…] Thank you for your consideration of my request.

Dr. Shenkin also gave me this text to help personlize the message:

CHS proposes to change the 96110 code from active test to screening, and thus exempt it from payment. This is both inaccurate and destructive. It is inaccurate because, contrary to the position taken by the American Academy of Pediatrics, many times the code does indeed represent testing. In my office I watch a child perform many tasks as I test their development. It is destructive because, by eliminating payment for 96110, CHS will deprive physicians of payment for developmental testing, and thus deprive children of rigorous evaluation of development.

I propose that no changes be made, and 96110 be retained in its former position.If there are changes to be made in the future, they should be studied more fully and better solutions developed.

Although Dr. Shenkin proposes something different from the AAP's
position, it's still something. Whatever you do, do something.  The link you need is here.

[Updated for 2013!]

[Updated on 10/11/12 to reflect the Revised RVU release.] 

Welcome to the free 2012 RBRVS Calculator.  Please note that this is in BETA, as it refers to
an annual conversion factor of $24.60. Past experience suggests that this number will change sometime between now (12/8/11) and March, 2012.

As you may know, the AMA won't let anyone provide a free RVU calculator that includes CPT codes due to their CPT copyrights. In an abundance of caution and, because in our unhappy experience, the American Medical Association interprets its rights (in our opinion) overly broadly, we created this tool for those of you who have a CPT license that allows for a use such as this. In theory, that should mean any practice that submits insurance claims.

To make a long story short, you can use this spreadsheet with the data that you can download from CMS to make a fairly sophisticated RVU calculator in about 5 minutes.

What does it do? It allows you to choose your CMS-driven location, set a Medicare Multiplier, and then, on a code-by-code basis, determine your pricing level. If you then take the time to include your code volume and pricing, it will determine your practice's FACF (i.e., how much you charge, on average, relative to Medicare). If you then provide your payment information, it will compare it to the Medicare fee schedule for you.

All around, pretty cool I say in all immodesty.

I have created both an OpenOffice version [revised 01/19/12] of the tool and, sigh, a Microsoft Excel version [revised 01/18/12] as well.

How does it work?

1. Download one of the above spreadsheets.
2. Head to CMS and download the 2012 RVU zip file. You have to agree to the license and usage rules from CMS, of course. My link above points to version A in 2012; CMS usually releases a few revisions through the year, but they usually don't affect pediatrics and primary care.
3. Extract the PPRRVU12.xlsx file from the zip file. Yes, I think it's completely lame that our federal government uses a proprietary format for this data, especially one (the new .xlsx) that not everyone who even owns Excel can open. Grrrrr.
4. Cut and paste the entire page of data from the PPRRVU12.xlsx file into the tab marked "PPRRVU12" in the RVU Calculator spreadsheet. Don't panic if it seems to freeze for a minute, it's a lot of data.
5. Choose your locality with the pulldown menu. Pick a Medicare Multiplier. Then, enter some CPT codes in column A. Gasp in amazement.
6. Put some unit volumes, prices, and payments in and watch what happens. Any field marked in a light blue-gray is a place where you can enter info.

I'd love for some guinea pigs to try this out and tell me what doesn't work. PCC clients, natch, can do this already with our reports, so I want to hear from the rest of you :-)

With the announcement that the AAP has updated its RBRVS guide for 2012, I guess I have to get off my duff and work on the 2012 RVUs.

Part 1: My annual  GPCI comparison.  AFAIK, this is still the only place where anyone actually breaks down the GPCI changes from year to year.  While some people jump up and down about a 1% change in a particular code or the annual conversion factor, we all need to pay attention to the GPCI scores.  For some parts of the country, the impact has been significant.  

What do we see this year?  Some big hits this year.  The average locality should expect a 1.76% decrease in their payments in 2012 before any changes to the CF or individual codes are taken into account.  OUCH.