8/18/2011 Learning Objectives: 77336: Maintaining the strength of the Continuing Medical Physics Consultation CPT ®code. • Understand the components of the work effort associated with the Continuing Medical Physics Consultation CPT© code (77336) • Understand how the code is valued and priced by Medicare • Offer opinions and comments on strategies to properly value the CPT© code 77336 • Implement procedures in the clinic that properly reflect the description of the code provided by AAPM and ASTRO Gerald A. White, Jr., M.S. Colorado Associates in Medical Physics Member, AAPM Professional Economics Committee Roadmap to Reimbursement Related Acronyms Essential to Medical Physicist Solvency (RÆMPS) • • • • • • • • CMS: Center for Medicare and Medicaid Services. The federal agency responsible for policy regarding Medicare and Medicaid Medicare Part A: The CMS basket that pays for inpatient services. Medicare Part B: The CMS basket that pays for Physician fees, technical costs in an outpatient setting, including hospital based outpatient Tx. Fiscal Intermediary: CMS contractor who manages Medicare Part A payments for a fixed (usually multi-state) area. Medical Carrier: CMS contractor who manages Medicare Part B payments for a fixed (usually multi-state) area. DRG: Diagnostic Related Groups. Classification system for hospital inpatients in which a single payment from CMS is made of all services associated with an admission. HOPPS: Hospital Outpatient Prospective Payment System. Classification system for hospital based outpatient Tx in which CPT © Codes are grouped into “similar” sets, each set is paid at a fixed rate CPT® Code: Classification system produced by the AMA in which medical procedures are described and assigned a 5 digit code for billing purposes. Roadmap to Reimbursement Related Acronyms Essential to Medical Physicist Solvency (RÆMPS) • • • • • • • • • APC: Ambulatory Payment Classification. The payment sets used for the HOPPS system. Modified annually. MFS: Medicare Physician Fee Schedule. List of CPT © codes and associated CMS payment rates. Modified annually. PC: Professional Component. The portion of the MFS CPT © code payment associated with the physician work effort TC: Technical Component: The portion of the MFS CPT © payment associated with the non-physician expense of delivering the service RVU: Relative Value Unit. Arbitrary unit used to rank the work effort associated with the PC of medical procedures. RUC: Relative Value Update Committee. Maintained by the AMA, evaluates the work effort and expense associated with the PC of CPT © codes and recommends values to CMS. PEAC: Practice Expense Advisory Committee. Maintained by the AMA, evaluates the work effort and expense associated with the TC of CPT © codes and recommends values to CMS. HCPCS: Health Care Common Procedure Coding System. A system analogous to the CPT© coding system, but maintained and valued by CMS. SGR: Sustainable Growth Rate. Congressionally mandated system that constrains the overall growth of certain Medicare expenditures 1 8/18/2011 77336 : Continuing Medical Physics Consultation 77336 : Continuing Medical Physics Consultation • CPT® 77336 Continuing medical physics consultation, including assessment of treatment parameters, quality assurance of dose delivery, and review of patient treatment documentation in support of the radiation oncologist, reported per week of therapy. • The continuing medical radiation physics consultation (CPT® code 77336) is used to describe the ongoing medical physics assessment provided by a qualified medical physicist to each patient receiving radiation therapy. 77336 : Continuing Medical Physics Consultation 77336 : Continuing Medical Physics Consultation • • • • • • • weekly chart reviews review and analysis of medical physics aspects of changes to the treatment regime consultation on patient setup and treatment modifications verification of dose calculation data reviewing accuracy of the current data record review of patient-specific therapist treatment and technical notes, patient radiation safety. ASTRO/ACR Guide to Radiation Oncology Coding ASTRO/ACR Guide to Radiation Oncology Coding The medical physicist will review all aspects of the treatment delivery, including correlating the treatment prescription with the technical and medical physics aspects of the treatment, and with the actual execution of the treatment. Appropriate modifications to the technical aspects of the patient treatment are formulated and the medical physicist will recommend implementation of these modifications, as required, in a timely fashion. ASTRO/ACR Guide to Radiation Oncology Coding 2 8/18/2011 77336 : Continuing Medical Physics Consultation The medical physicist will review all aspects of the treatment delivery, including correlating the treatment prescription with the technical and medical physics aspects of the treatment, and with the actual execution of the treatment. Appropriate modifications to the technical aspects of the patient treatment are formulated and the medical physicist will recommend implementation of these modifications, as required, in a timely fashion. 77336 : Continuing Medical Physics Consultation • Patient status review at weekly chart rounds • Daily planning conference • Tumor Board • Site specific patient review conferences White’s Handy Guide to Radiation Oncology Procedures ASTRO/ACR Guide to Radiation Oncology Coding 77336 : Continuing Medical Physics Consultation ABT Valuation • ABT I: 1.5 hours per patient • ABT II: 1.5 hours per patient • ABT III: 1 hour per patient 77336 : Continuing Medical Physics Consultation Practices without a full-time medical physicist must have regular on-site physics support during hours of clinical activity at least 2 days a week and provide 0.4 full time equivalents (FTE) coverage. ACR TECHNICAL STANDARD FOR THE PERFORMANCE OF RADIATION ONCOLOGY PHYSICS FOR EXTERNAL BEAM THERAPY 3 8/18/2011 77336 : Continuing Medical Physics Consultation 77336 : Continuing Medical Physics Consultation Practices without a full-time medical on-site physicist must have regular physics support during hours of clinical activity at least 2 days a week and provide 0.4 full time equivalents (FTE) coverage. ACR TECHNICAL STANDARD FOR THE PERFORMANCE OF RADIATION ONCOLOGY PHYSICS FOR EXTERNAL BEAM THERAPY 77336 : Continuing Medical Physics Consultation • Billed once every 5 fractions of treatment (routine external beam course) – Group by 5 fractions or on a specified day each week • Rule: Divide by 5, round to nearest integer – 18 fx: 4 instances of 77336 – 17 fx: 3 instances of 77336 77336 : Continuing Medical Physics Consultation -Documentation • Documentation of these services should include a signed and dated indication by the medical physicist in the patient’s chart that the continuing medical physics consultation has been done. ASTRO/ACR Guide to Radiation Oncology Coding • Electronic Charts ease this process • Treatment course of 1 or 2 fractions – 1 instance of 77336 4 8/18/2011 77336 : Continuing Medical Physics Consultation -EDITS Can I Get Paid Now? • Note numerous CCI edits, but a modifier is allowed for many • Confusion regarding IMRT and 77336- CCI edit with no allowed modifiers – Applies to the IMRT planning process (77301), not the treatment delivery process Annual Revenue 77336 Patients per week 25 ABT Hours MFS Annual $ 25 $59,800 Hopps Annual $ $135,200 50 50 $119,600 $279,400 75 75 $179,400 $405,600 100 100 $239,200 $540,800 5 8/18/2011 HOPPS Valuation • Based on Hospital Charges • Reduced by Cost to Charge Ratio • Generally single charge events • Review your Department Charge Master • Be aware of the local Cost to Charge Ratio • Estimate the time and resources necessary to perform 77336 for a typical patient. MFS Payment Calculation • Payment Calculation MFS Valuation • Subject to new calculation methodology • Subject to changes in the Conversion Factor – Total RVU = (Work RVU * Work GPCI) + (PE RVU * PE GPCI) + (PLI RVU * PLI GPCI) • Total Payment = Total RVU * $$Conversion HOPPS Valuation – Sustainable Growth Rate calculation problems Factor 6 8/18/2011 MFS Valuation MFS Valuation – AAPM role • Increased value will depend on a re-evaluation of the underlying work effort of the Medical Physicist, consistent with current practice and ABT reports • Recognition of increased complexity since initial valuation • CMS acceptance of current AAPM Salary Survey levels • Appropriate allocation of MP time MFS Valuation – MP role • Personally perform the tasks associated with 77336 • Appropriate on-site presence in all practice settings • Encourage peer compliance with MP effort in 77336 • Patience 7