Q: Are there any new codes?
A: Yes. The Health Care Procedure Coding System (HCPCS) gets releases in both January and July. All of the following codes are in effect as of July 1, 2020; the first three are for the various parts of reporting remotely-performed OCT of the retina (the measurement is done by the patient).
• 0604T—Optical coherence tomography (OCT) of retina, remote, patient-initiated image capture and transmission to a remote surveillance center unilateral or bilateral (this is for the initial device provision, set-up, and patient education on the use of the equipment).
• 0605T—The same as 0604T, but this code is used by a remote surveillance center which provides technical support, data analyses and reports, with a minimum of eight daily recordings, over a 30-day time span.
• 0606T—The same as 0604T, but covers the review, interpretation and report by the prescribing physician or other qualified health professional of remote surveillance center data analyses over a 30-day time span.
Note: Don’t report 0604T, 0605T, 0606T in conjunction with 99457 or 99458.
The next code is:
• 0615T—Eye-movement analysis without spatial calibration, with interpretation and report (don’t report 0615T in conjunction with 92540, 92541, 92542, 92544, 92545, 92546 or 92547).
The next three codes are for actually implanting an artificial iris in different clinical settings. A device code (C1839) was already established for use in January 2020. The device code itself has pass-through payment status under Medicare and you should report both the device code and one of the codes listed below.
• 0616T—Insertion of iris prosthesis, including suture fixation and repair or removal of iris, when performed without removal of crystalline lens or intraocular lens, without insertion of intraocular lens. Use this code when you perform only the artificial iris implantation.
• 0617T—This code is for artificial iris implantation and removal of the crystalline lens with insertion of an IOL (don’t report 0617T in conjunction with 66982, 66983, 66984).
• 0618T-—This code is for artificial iris implantation with secondary intraocular lens placement or intraocular lens exchange (don’t report in conjunction with 66985 or 66986).
Note: Don’t report 0616T, 0617T, 0618T in conjunction with 66600, 66680 or 66682.
Since the above codes are new and, as of this writing, there’s no published coverage or payment information, be sure to check your Medicare Administrative Contractor’s website after July 1 for updates.
Q: I’m still dealing with significant issues due to COVID-19 and I think it might affect my ability to report 2020 MIPS data. I don’t want to be penalized in the future. Is there any help available in this area?
A: Yes. In mid-June, CMS made two hardship exceptions available for the 2020 performance year. The first applies only to the electronic medical records area of MIPS (known as Promoting Interoperability, or PI). While there are a number of possible reasons to consider this hardship exception, CMS does state that one of the possibilities is that you “face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress….” If granted, you would have this MIPS area, which makes up 25 percent of the total scoring, re-weighted unless you later choose to submit data in this category.
The second hardship exception is broad, and is defined as being for “Extreme and Uncontrollable Circumstances.” CMS notes this might be considered in the following scenarios:
• you’re unable to collect information necessary to submit for a MIPS performance category;
• you’re unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the Quality performance category for three months); and/or
• the circumstances impact your normal processes, affecting your performance on cost measures and other administrative claims measures.
If the second hardship exception is granted, all four MIPS categories are re-weighted to 0 percent and you’re not penalized in 2022—but you can’t earn a bonus unless you later decide to submit data for 2020 and subsequently achieve a big enough MIPS score.
You can access the information and applications for these hardship exceptions at qpp.cms.gov/mips/exception-applications. You can apply for these exceptions through December 31, 2020.
Q: Is there any new information on the 2021 ICD-10 codes that come into effect in October 2020?
A: While it’s not final as of this writing (but will be soon), the panel in charge of the new and revised codes met in March and posted their minutes on the official CDC website. A sampling of the new proposed codes that affect ophthalmology are as follows:
• we may finally get a “real code” for pseudoexfoliation of the lens not involving glaucoma in the H27.81 area;
• Stargardt’s Disease appears destined to get its own code in the H35.55 area; and
• minor changes may be made to the Z01 area and the Z79 area.
Q: Are there any July 2020 National Correct Coding Initiative (NCCI) edits that affect ophthalmology?
A: There’s one in particular that eye surgeons should be aware of. The code combination of 66174 (Transluminal dilation of aqueous outflow canal; without retention of device or stent) and 65820 (Goniotomy) has a new “mutually exclusive” edit, which means that the codes can’t be billed on the same eye in the same surgical session. Before July 1, 2020, there were no NCCI edits bundling these two codes, which meant offices and ASCs could still bill both codes together. However, CPT’s publisher, the American Medical Association, via its CPT Assistant publication, noted in December 2018 and September 2019 that the codes shouldn’t be billed together. As a result of the new NCCI edits, AMA and CMS now agree that even if you do perform both procedures, you should only bill for 66174. It’s also likely that other payers will agree, but you should check.
In terms of payment, looking at national Medicare payments, this negatively affects surgeons (a loss of about $400). ASCs would get a $459 reduction. Hospital outpatient department claims won’t change at all, due to the way the comprehensive Ambulatory Payment Classification works, which only pays for one of the codes anyway.
Q: I’ve seen some discussion about having patients pay us for the extra cost of all the personal protective equipment we need to have to protect everyone (staff, doctors and patients) from coronavirus infection.
A: Unfortunately, supplies used to care for your patients are already part of your claims and payment. No charge to the patient is warranted, either. REVIEW
Mr. Larson is a senior consultant at the Corcoran Consulting Group and is based in Atlanta. He welcomes any comments or questions on the topic of this month’s column.
Please contact him at email@example.com.