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of the many values of ASA membership is the very
hard work that its staff, officers and committee
members apply to pain practice management issues.
Notably the staff and officers closely cooperate
with other organizations that represent pain medicine
physicians. This work provides a bulwark for the
pain medicine specialist against the sometimes irrational
tides of regulation and payer policies that seem
to surge daily against our practices and our patients.
The committees on Economics and Pain Medicine and
the ASA staff and officers have worked in concert
this past year on a number of issues important to
ASA members’ pain medicine practice management.
1. Coding Issues: New technology
and practice patterns require ongoing evaluation
of the codes we use to describe the services we
provide to our patients. This year ASA has considered
the codes applied to paravertebral nerve blockade,
kyphoplasty, vertebroplasty, selective nerve root
injection and “pulsed” radio-frequency
denervation. The two committees and staff have worked
to create the necessary information to usher new
codes or re-appraisals of existing codes through
the very complex process of approval via the American
Medical Association (AMA) Current Procedural Terminology™
(CPT) Editorial Panel and the American Medical Association/Specialty
Society Relative Value Scale Update Committee (RUC),
in accordance with Medicare’s Resource-Based
Relative Value Scale (RBRVS) system, the determinant
of most physician payment.
The key to successful code acceptance is to present
to the CPT Editorial Panel a cogent argument describing
need and an accurate definition and indications.
Once a new code or revision is approved, a proper
value must be assigned to it. Valuation requires
that the sponsoring specialty society canvass its
members to glean the facts regarding realistic work
values and practice expenses associated with each
procedure. ASA members can greatly contribute to
these efforts by participating in surveys when asked
to do so. A society can make a stronger argument
to the RUC when it has a large survey response.
There is a congressional mandate that RBRVS physician
work values be reviewed at least every five years.
The third Five-Year Review is under way as this
article is written, and ASA has joined the American
Academy of Pain Medicine, the North American Spine
Society and the American Association of Neurological
Surgeons/Congress of Neurological Surgeons in requesting
a re-evaluation of the work associated with spinal
cord stimulator placement as well as intrathecal
and epidural pump implantation. By the time you
read this, we hope that the members have responded
in large numbers to the surveys that were distributed,
or the data may carry little value when the codes
are reviewed by the RUC.
2. Review and comment on regional Centers
for Medicare & Medicaid Services (CMS) carrier
reimbursement policies: When new policies
or decisions are adopted by a local Medicare carrier,
or if decisions are pondered at the Carrier Advisory
Committee (CAC), it may be helpful to the practitioner,
the carrier and the CAC if ASA provides perspective
on reimbursement policy. In that situation, the
ASA staff works with the local medical community,
especially the ASA CAC member. An ASA member serves
on every CAC, and ASA has advised all state societies,
who choose the CAC representatives, to ensure that
either the principal or alternate representative
has an active pain practice. Every member should,
however, monitor his or her own local carrier’s
policies when they are in the development stage
<www.cms.hhs.gov/mcd/search.asp>.
If there is an issue of significance, please call
the ASA Washington Office at (202) 289-2222 to alert
either Assistant Director of Governmental Affairs
(Regulatory) Karin Bierstein or Coding and Reimbursement
Analyst Sharon Merrick, who spend all of
their free time reading anesthetic payment policy
literature.
This past year, ASA has advocated on behalf of pain
medicine practice in the private and governmental
realms, including issues regarding somatic nerve
block policies by the CMS carriers Noridian and
Empire and edits of the McKesson software used by
private payers to help determine payment policies.
The ASA Washington Office also has worked with Administar,
administrator of the National Correct Coding Initiative
(NCCI), which is the software used by Medicare carriers
regarding payments for pain and anesthesia. NCCI
edits are updated quarterly and are available on
the CMS Web site at <www.cms.hhs.gov/physicians/cciedits/default.asp>.
Other topics monitored by the committees include
CPT Assistant advisories on facet injections and
payer concerns about “acceptable” lifetime
dosage of steroids in the epidural space, frequency
of injection therapy for complex regional pain syndrome,
pulsed versus “original” radio-frequency
ablation coding, ultrasound guidance for regional
anesthetic placement and the use of sedation for
facet injections.
3. Pay for Performance: This initiative,
recently embraced by CMS and other payers, would
eventually link health care provider payment to
outcome measures. Presently it appears that indicators
of process (how care is delivered) rather than of
outcome (how well patients responded) will be the
monitored and “rewarded” measurements.
Eventually it is expected, however, that actual
clinical outcomes will be linked to the magnitude
of provider reimbursement.
While provider skepticism is understandable, this
initiative is moving forward, and we are challenged
to help guide the choice of measurements toward
those most likely to fulfill two requirements:
• The variable’s measurement will
not decrease the cost of “unnecessary”
care.
• The variable has a valid reflection to
patient care quality.
It will be important for ASA and each of its members
to be proactive in helping to develop these measures
in concert with payers and CMS. Ms. Bierstein and
Director of Governmental Affairs and General Counsel
Ronald Szabat in ASA’s Washington Office are
very involved in this issue and can answer ASA members’
questions on this topic.
In summary use the resources cited above and be
alert to changes in the economics surrounding pain
practice in your area. If you have any concerns,
contact ASA, an emphatic advocate for the patients
and practices of the anesthesiologist who is involved
in pain medicine.
The author acknowledges without embarrassment
that most of the accuracies and useful information
in this article were ghostwritten by Ms. Bierstein
and Ms. Merrick. Any inaccuracies are his own.
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Douglas G. Merrill, M.D., is Staff Anesthesiologist,
Virginia Mason Clinic, Seattle, Washington. |
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