NEUROMODULATION
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On July 13, 2021, the Centers for Medicare and Medicaid Services (CMS) published the CY 2022 Medicare Physician Fee Schedule (MPFS) Proposed Rule. The Rule provides CMS’ proposed changes to policy and payment rates for physician services provided on or after January 1, 2022.

CMS has proposed to NOT extend coverage of Neurological services (Neurostimulator Analysis and Programming) furnished via telehealth on conclusion of the Public Health Emergency (PHE).

 

Item Current Proposed

CPT‡ Codes 95970, 95971, 95972, 95983 and 95984 (full description of codes below)

Added to Medicare's temporary list of Telehealth services for the duration of the PHE*.
Codes are considered covered, and therefore billable via telehealth for Medicare patients implanted with a Spinal Cord Stimulator or Deep Brain Stimulator device.

No longer billable via Telehealth for Chronic Pain and Movement Disorder patients after the conclusion of the PHE*.

 

* As of this writing, a PHE expiration date has not been declared.

Category 3 Designation

During the PHE, CMS established a Category 3 telehealth designation. Services that were added on a temporary basis will ultimately need to fulfill criteria in order to be added to the permanent Medicare telehealth services list. A category 3 telehealth designation allows additional time for stakeholders to collect, analyze and submit data.

CMS is soliciting comment on whether the codes listed above should now be transitioned to to the Medicare telehealth list on a Category 3 basis to allow time for additional data collection.

Guide to submitting comments

CMS will be accepting public comments on this proposal until September 13, 2021, 5:00 PM ET. Comments may be submitted through Regulations.Gov website.

Key considerations to address:

  • Proposed Non-Coverage of the remote programming CPT codes after the PHE is declared over
  • Review the clinical benefit of remote programming within your practice and/or institution
    • Pain Physicians: Demonstrate that remote programming (programming delivered via telehealth) improves the treatment of Chronic Pain patients implanted with a spinal cord stimulator
    • Movement Disorder Physicians: Demonstrate that remote programming (programming delivered via telehealth) improves the treatment of Deep Brain Stimulation patients implanted with a neurostimulator.
    • Examples of clinical benefit include the following:
      • Ability to diagnose a medical condition in a patient population without access to clinically appropriate in-person diagnostic services
      • Treatment option for patient population without access to clinically appropriate in-person treatment option
      • Reduced rate of complications
      • Decreased rate of subsequent diagnostic or therapeutic interventions (i.e. due to reduced rate of recurrence of the disease process)
      • More rapid beneficial resolution of the disease process treatment
      • Decreased pain, bleeding or other quantifiable symptom
      • Reduced recovery time
  • Explain any access challenges faced by your center, as well as the importance of improving telehealth access and digital health for Medicare patients
  • Provide your recommendation on appropriate telehealth coverage guidelines for Medicare so that beneficiaries may continue to access remote programming

QUESTIONS?

If you have any questions related to the CY 2022 Medicare Physician Fee Schedule (MPFS) Proposed Rule, or the comment period, please e-mail Neuro_Reimbursement@abbott.com.

Full description of impacted codes

CPT‡ Code Description

95970

Electronic analysis of implanted neurostimulator pulse generator/transmitter (e.g., contact group[s], interleaving, amplitude, pulse width, frequency [Hz], on/off cycling, burst, magnet mode, dose lockout, patient selectable parameters, responsive neurostimulation, detection algorithms, closed loop parameters, and passive parameters) by physician or other qualified health care professional; with brain, cranial nerve, spinal cord, peripheral nerve, or sacral nerve, neurostimulator pulse generator/transmitter, without programming.

CHRONIC PAIN PROGRAMMING AND ANALYSYS CODES

95971

Electronic analysis of implanted neurostimulator pulse generator/transmitter (e.g., contact group[s], interleaving, amplitude, pulse width, frequency [Hz], on/off cycling, burst, magnet mode, dose lockout, patient selectable parameters, responsive neurostimulation, detection algorithms, closed loop parameters, and passive parameters) by physician or other qualified health care professional; with simple spinal cord or peripheral nerve (e.g., sacral nerve) neurostimulator pulse generator/transmitter programming by physician or other qualified health care professional

95972

Electronic analysis of implanted neurostimulator pulse generator/transmitter (e.g., contact group[s], interleaving, amplitude, pulse width, frequency [Hz], on/off cycling, burst, magnet mode, dose lockout, patient selectable parameters, responsive neurostimulation, detection algorithms, closed loop parameters, and passive parameters) by physician or other qualified health care professional; with complex spinal cord or peripheral nerve (e.g., sacral nerve) neurostimulator pulse generator/transmitter programming by physician or other qualified health care professional

DEEP BRAIN STIMULATION PROGRAMMING AND ANALYSIS CODES

95983

Electronic analysis of implanted neurostimulator pulse generator/transmitter (e.g., contact group[s], interleaving, amplitude, pulse width, frequency [Hz], on/off cycling, burst, magnet mode, dose lockout, patient selectable parameters, responsive neurostimulation, detection algorithms, closed loop parameters, and passive parameters) by physician or other qualified health care professional; with brain neurostimulator pulse generator/transmitter programming, first 15 minutes face-to-face time with physician or other qualified health care professional

95984

Electronic analysis of implanted neurostimulator pulse generator/transmitter (e.g., contact group[s], interleaving, amplitude, pulse width, frequency [Hz], on/off cycling, burst, magnet mode, dose lockout, patient selectable parameters, responsive neurostimulation, detection algorithms, closed loop parameters, and passive parameters) by physician or other qualified health care professional; with brain neurostimulator pulse generator/transmitter programming, each additional 15 minutes face-to-face time with physician or other qualified health care professional (List separately in addition to code for primary procedure)

‡ Indicates a third party trademark, which is property of its respective owner.


HE&R Disclaimer: 

This document and the information contained herein is for general information purposes only and is not intended, and does not constitute, legal, reimbursement, business, clinical, or other advice. Furthermore, it is not intended to and does not constitute a representation or guarantee of reimbursement, payment, or charge, or that reimbursement or other payment will be received. It is not intended to increase or maximize payment by any payer. Similarly, nothing in this document should be viewed as instructions for selecting any particular code, and Abbott does not advocate or warrant the appropriateness of the use of any particular code. The ultimate responsibility for coding and obtaining payment/reimbursement remains with the customer. This includes the responsibility for accuracy and veracity of all coding and claims submitted to third-party payers. In addition, the customer should note that laws, regulations, and coverage policies are complex and are updated frequently, and, therefore, the customer should check with its local carriers or intermediaries often and should consult with legal counsel or a financial, coding, or reimbursement specialist for any questions related to coding, billing, reimbursement or any related issues. This material reproduces information for reference purposes only. It is not provided or authorized for marketing use.

 

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