Title 22 Payments
We had about 60 responses to the initial query about the lack of payment for second assistants from Noridian the Medicare vendor. The problem was nearly universal.
CASTS leadership has had multiple points of contact with Noridian, including a meeting with its director Bernice Hecker MD. We informed them of the unique role of Title 22 in the state of California in requiring a second assistant. Our understanding at this point is that Noridian will be open to paying for the second assistant as long as its role is documented properly. We have heard some feedback from members who are now starting to get paid for a second assistant. Below is a sample composite template on how to document appropriately the role of the first and second assistants, based on some of the responses we have received form members. A follow up meeting was held between CASTS leadership and Noridian at the Medicare Carrier Advisory Committee meeting in San Francisco last month. The following the statement was issued after that meeting. Not completely satisfying, but something we can work with. An alternate proposal for billing the vein harvest as co-surgeon was discussed and though this might lead to slightly higher short term compensation, but I did not think this was a good long term solution, ie if/when the vendor changed again and since it did not resolve the non cabg cases.
Dr. Hecker submitted the following statement:
“Esteemed Colleagues, Noridian has received a number of appeals (redeterminations) related to denials for reimbursement of services of a second assistant during open heart surgery. At the redeterminations level, we have been able to make several individual determinations favorable to the appellant based on additional information submitted. This process, however, remains a mutually time-consuming, resource-intensive interim solution. Moreover, a number of claims have remained denied due to the absence of documentation supporting the need or even a role for the second assistant other than fulfillment of a state requirement which is unrelated to medical necessity. We have sought advice from CMS, providers and specialty societies across our states, legal staff, and all on this email but have not yet been able to identify a solution(s) or other resolution to this situation. From our perspective, and that of essentially all with whom we have spoken, Title 22 may need to be re-addressed in light of current national practice and the requirements of Medicare and other payers. In the interim, careful documentation of the specific roles of the assistants is fundamental to payment. We are not allowed to change the Medicare law, but we will do whatever we are allowed to do to assist you.
My regards to each of you,”
Bernice Hecker MD, MHA, FACC, Executive Medical Director, Medicare, Parts A&B, Jurisdiction E (CA, HI, NV, Guam, Samoa, CNMI)
Suggested wording for operative reports:
The 2nd assistant performed saphenous vein harvest and preparation, followed by closure of the incision. Simultaneously, the first assistant assisted with cannulation and placing the patient on cardiopulmonary bypass. The first assistant remained throughout the construction of all proximal and distal anastomoses, and weaning the patient off bypass. When the 2nd assistant finished closing the leg, he/she moved to the chest, to assist with suctioning, retraction, and exposure. Once the patient was off bypass, the 2nd assistant assisted with closure of the wound.
Sternotomy AVR & MVR
The 1st assistant was present from the time of cannulation for cardiopulmonary bypass, to the completion of valve implantation (or repair) until the patient was successfully weaned off cardiopulmonary bypass. The 2nd assistant was present throughout the entire operation, and assisted with retraction, suction, and exposure. The 2nd assistant also held the valve prosthesis during suture placement into the sewing ring to expedite implantation and reduce ischemic time.
SB830, enhancing public reporting to include PCI, continues to make its way through the state legislature committee structure. CASTS was asked to and did provide a letter of support for the legislation.
It was held up due to budgetary concerns, ie cost. We are working with CA-ACC to try to help reduce the cost by importing currently available data from cath labs. More to follow. Dr McMillan is leading the charge for CASTS on this topic.
The CASTS reporting website has been completely revised and updated. The draft version is at www.californiacardiacsurgery.com/CCSIP-2012. The hospital needs to pay a fee to see comparative data. At present this is the only source of comparative data for California heart hospitals. It is rigorously documented and offers a source of information in advance of public reporting, which will take a few years to get off the ground. CASTS would like to enlist hospital participation in QI collaboratives, offering access to the website and regional meetings for an annual fee. We would like your support in the endeavor. Please enlist your data managers’ and hospital administrators’ help in supporting this initiative. The annual fee is really a small amount, so far only a few hospitals have paid. This is the easiest way to secure the financial viability of CASTS.