As many of you are aware, the CPT Editorial panel has eliminated CPT Code 95920, the Intraoperative Neuromonitoring (IONM) service, effective January 1, 2013. In its place, two new CPT codes have been established: Code 95940, which describes continual one-on-one monitoring performed in the operating room; and Code 95941, defined as IONM from outside the operating room (remote or nearby), which can be used to report monitoring of more than one patient concurrently.
In the 2013 Medicare Physician Fee Schedule final rule, CMS indicated that code 95941 would not be recognized by Medicare and established a new G code—G0453—for reporting monitoring from outside the operating room but limited the service to one patient. This decision will present major problems for access to care beginning January 2013 since there are not enough qualified professionals to perform one-on-one monitoring for all the surgical patients needing this service.
The AAN and the American Clinical Neurophysiology Society (ACNS) are meeting with CMS next week to urge that a solution be found as soon as possible to permit multiple patients to be monitored concurrently to avoid any deterioration in the quality of surgical care requiring IONM services. The organizations are asking CMS to consider the precedent used for anesthesiology whereby up to four concurrent cases can be medically directed by an anesthesiologist at a reduced rate. Specifically, we are seeking a second G code for remote monitoring of multiple patients and that on an interim basis the payment rate for the second G code be equal to 50 percent of the rate assigned to G0453.
Call to Action:
The AAN and ACNS are encouraging their members to submit comments on the Medicare final rule. In your comments we would like you to ask for the interim remedy to this problem, which we will be presenting to CMS next week, and to ask that CMS establish a refinement panel to reconsider the values of the new G codes for IONM to take effect in 2013. Below, we provide you with directions on how to submit comments and draft language you can use in your comment letter.
The deadline for submitting comments is 5:00 p.m. ET, December 31, 2012.
Note that submissions will be posted publicly.
How to Submit Comments:
Prepare your text in advance. Comments are submitted electronically. You will need to enter your contact information and letter as directed. Make sure you include this file code in your submission: CMS-1590-FC. Please send a copy of your comments to email@example.com.
Sample Comment Letter:
Ms. Marilyn B. Tavenner
Acting Administrator, Centers for Medicare & Medicaid Services
Department of Health and Human Services
RE: CMS-1590-FC, 2013 Medicare Physician Fee Schedule Final Rule
Dear Ms. Tavenner,
I am a [give your specialty] who routinely uses Intraoperative Neurophysiologic Monitoring (IONM) to prevent neurologic injury in the operating room. I am concerned with the policy CMS has established for intraoperative neuromonitoring (IONM) in the 2013 Medicare Physician Fee Schedule Final Rule. I believe that this policy will not only severely restrict patient access but also will add to the cost of medical care for the Medicare system.
[Provide some information about your practice: The type of surgeries that you monitor, that you supervise trained technologists who are present in the operating room, why IONM is used during surgery, how it has improved safety and patient outcomes. Explain that Medicare costs will increase if neurological injuries occur due to the reduced use of IONM.]
Effective, January 1, 2013, the existing IONM CPT code 95920 will be deleted and will be replaced by two new codes—95940 and 95941. Code 95940 describes continual one-on-one monitoring performed in the operating room and Code 95941 is defined as IONM from outside the operating room (remote or nearby) which can be used to report monitoring of more than one patient concurrently. For 2013, CMS has decided not to recognize 95941 for Medicare purposes and established a temporary “G” code, G0453, Continuous Intraoperative neurophysiology monitoring, from outside the operating room with attention directed exclusively to one patient.
We believe that limiting the use of the G0453 to monitoring a single patient will present major problems. By limiting the use of Code G0453 to a single patient, thousands of surgical patients will be denied access to IONM services because there will not be enough qualified professionals performing this valuable service to provide only one-on-one monitoring of remote cases. My concern is shared by many neurologic and surgical societies.
I ask that CMS to reconsider this decision. On an interim basis, I urge that CMS implement the recommendation of the American Academy of Neurology and the American Clinical Neurophysiology Society to establish a second G code for remote monitoring of up to four patients with a reduced payment rate for 2013. I understand that this follows the model that CMS recognizes for anesthesiology.
For implementation in the 2014 Medicare Physician Fee Schedule, I also ask that CMS increase the work value assigned to G0453 so that it is equal to the work value assigned to CPT Code 95940. The physician time and effort for both of these services is identical and a work value of 0.60 should be assigned to both codes.
Thank you for your consideration.
[Add your name]