PLEASE NOTE: THIS RESOLUTION WILL BE DEBATED AT THE 2015 COUNCIL MEETING. RESOLUTIONS ARE NOT
OFFICIAL UNTIL ADOPTED BY THE COUNCIL AND THE BOARD OF DIRECTORS (AS APPLICABLE).
RESOLUTION:
27(15)
SUBMITTED BY:
Missouri College of Emergency Physicians
SUBJECT:
Reimbursement for Ultrasound Performed by Emergency Physicians
PURPOSE: Issue a statement declaring emergency physicians should be paid for performing and interpreting
ultrasound studies and support efforts to reduce payment denials.
FISCAL IMPACT: Budgeted committee and staff resources.
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WHEREAS, Incorporation of clinical ultrasound in the Emergency Department improves patient safety
and is an invaluable tool in the diagnosis, resuscitation, and management of patients in the Emergency
Department; and
WHEREAS, The ability to perform clinical ultrasound studies and services in the Emergency Department
is an essential skill of all emergency physicians; and
WHEREAS, Becoming proficient in clinical ultrasound studies and services requires dedication, practice,
and skill; and
WHEREAS, Ultrasonography is a required component and part of the curriculum of Emergency Medicine
training programs as outlined in the Model of the Clinical Practice of Emergency Medicine; and
WHEREAS, As part of the Emergency Medicine Milestone Project, proficiency in Emergency Medicine
ultrasonography is included as a sub-competency (PC-12) of Emergency Medicine; and
WHEREAS, Graduates of Emergency Medicine residency programs are expected to be proficient in goaldirected, focused ultrasound studies and procedures; and
WHEREAS, Several national insurance payers have started to reject payments for ultrasounds performed
by Emergency Medicine providers on Emergency Department patients; and
WHEREAS, In Missouri, several payers have bundled the performance of clinical ultrasonography
performed by Emergency Medicine providers into the standard E/M payment codes; and
WHEREAS, Clinical, goal-directed, focused ultrasound studies and services are distinct and separate
clinical procedures and therefore should be reimbursed as such; therefore be it
RESOLVED, That ACEP issue a statement declaring that insurance companies and other payers
reimburse emergency physicians for ultrasound studies and services that they perform and interpret as part of
patient care in the Emergency Department; and be it further
RESOLVED, That ACEP support efforts to reduce payment denials for appropriately performed and
documented clinical ultrasonography.
Resolution 27(15) Reimbursement for Ultrasound Performed by Emergency Physicians
Page 2
Background
The resolution calls for ACEP to issue a statement declaring that emergency physicians should be paid for
performing and interpreting ultrasound studies and to support efforts to reduce payment denials.
ACEP’s “Emergency Ultrasound Guidelines” state: “documentation of emergency ultrasound procedures should
result in an appropriate reimbursement for services provided.” Additionally, ACEP’s policy statement, “ Fair
Payment for Emergency Department Services,” reinforces the need for fair payment for emergency services.
The policy statement, “Interpretation of Imaging Diagnostic Studies,” states: “The American College of
Emergency Physicians (ACEP) believes that the quality of patient care is enhanced when emergency physicians
interpret and record the results of the diagnostic studies they order at the time of service.” The policy further states
“The emergency physician providing contemporaneous interpretation of a diagnostic study is entitled to
reimbursement for such interpretation even if the study is reviewed subsequently as part of the quality control
process of the institution in which the physician practices.” However, this policy does not specifically mention
ultrasound services.
Along with the national Reimbursement Committee and Coding & Nomenclature Advisory Committee, ACEP
has a large and active Emergency Ultrasound Section that helps monitor the ultrasound reimbursement
environment at the national and regional payer level. These groups have reported an increase in payer polices to
bundle diagnostic testing, including ultrasound services, into the ED evaluation and management (E/M) service
reported on the same day. Information regarding appropriate coding and documentation are available on the
ACEP Emergency Ultrasound Section website. Resources to defend these practices are available in the
reimbursement area of the ACEP website including templated letters for appealing denied claims and FAQs
outlining the requirements for successfully reporting ultrasound services. ACEP’s RUC Teams have advocated
for fair payment for diagnostic services with CMS. Additionally, ACEP has directly challenged private payers,
including Aetna, Humana, Blue Cross and Anthem WellPoint, that had inappropriately bundled ultrasound
services into the ED E/M codes, when they do not similarly target other medical specialties.
Some insurers have argued that clinical ultrasound performed in the emergency department is not part of an
accredited program and there is no external validation of the quality of those procedures. In response, and as part
of an overall program to ensure quality and patient safety, ACEP created the Clinical Ultrasound Accreditation
Program (CUAP) which launched this past year. Programs may apply on line, providing appropriate
documentation of training and clinical oversight through the ACEP website at www.acep.org/CUAP/. Several
programs have already been accredited and are listed on the website.
ACEP Strategic Plan Reference
Promote emergency medicine as an essential part of the health care system and use communication tools to help
position emergency physicians to participate in new payment models.
Collaborate with the AMA, state medical societies, and other medical organizations on payment and practice
sustainability issues, including interaction with entities such as FAIR Health, NCOIL, NAIC, and PAI, as
appropriate.
Develop work value recommendations on the ED-relevant identified codes that have not been through the RUC
survey process to ensure values are maintained or increased. Begin preparations for the 2017 Five-Year-Review.
Identify payers that do not pay fairly and consider compliance disputes and legal actions through the most
strategic available mechanisms.
Identify and monitor evolving payment methodologies and investigate strategies for emergency medicine to
prosper under those most likely to prevail.
Create and promote resources on fair payment issues for the membership.
Resolution 27(15) Reimbursement for Ultrasound Performed by Emergency Physicians
Page 3
Continue to share EM Value findings from the RAND study with Congress and key policymakers
Promote key messages to increase awareness about the pivotal role of emergency physicians and their ability to
save money in health care costs. Increase visibility of emergency physicians as leaders in health care.
Fiscal Impact
Budgeted committee and staff resources.
Prior Council Action
Amended Substitute Resolution 42(90) Ultrasound adopted. Directed ACEP to support and encourage the
immediate availability of ultrasound technology for ED patients by appropriately trained and credentialed
physicians, including emergency physicians; develop guidelines by which an emergency physician would be
considered to be appropriately trained; and work with third-party payers to insure that emergency physicians
receive fair and appropriate reimbursement for providing ultrasound diagnostic services in emergency facilities –
adopted.
Prior Board Action
The Board has supported prior compliance disputes with Aetna, Humana, and Anthem/WellPoint regarding those
payers inappropriately bundling diagnostic interpretations into the ED E/M visit.
January 2015, granted final approval for the Clinical Ultrasound Accreditation Program.
January 2015, approved the Clinical Ultrasound Accreditation Program governance charter.
April 2014, approved the appointments to the Clinical Ultrasound Accreditation Program Board of Governors.
February 2013, approved the revised policy statement, “Interpretation of Imaging Diagnostic Studies;” approved
June 2006; reaffirmed October 2000; revised and approved September 1996; originally approved as
“Interpretation of Diagnostic Studies” March 1990.
April 2011, approved the continued development of the Clinical Ultrasound Accreditation Program.
October 2010, sunset the policy statement, “Use of Ultrasound Imaging by Emergency Physicians;” approved
June 1997; revised and approved June 2001; replaced “Use of Ultrasound for Emergency Department Patients”
January 1991.
October 2008, approved the revised policy statement, “Emergency Ultrasound Guidelines;” originally approved
June 2001.
October 2008, approved the development of an ultrasound accreditation program.
Amended Substitute Resolution 42(90) Ultrasound adopted.
Background Information Prepared by: David McKenzie, CAE
Reimbursement Director
Sandy Schneider, MD, FACEP
Emergency Medicine Practice Director
Reviewed By: Kevin Klauer, DO, EJD, FACEP, Speaker
James Cusick, MD, FACEP, Vice Speaker
Dean Wilkerson, JD, MBA, CAE, Council Secretary and Executive Director