SIR and its members are dedicated to improving public health through pioneering advances in minimally invasive, image-guided therapies.
Regulatory comment letters
CMS issues 2020 interim final rule for COVID-19 regulatory changes
On, March 13, 2020, the Centers for Medicare and Medicaid Services (CMS) released an interim final rule for COVID-19 regulatory changes. This is a modification to the original 2020 final rule published on Nov. 1, 2019, for the Medicare Physician Fee Schedule (MPFS).
The final rule was published on Nov. 15, 2019, and posted here. The MPFS addresses Medicare rates and policies under Part B, as well as the Quality Payment Program (QPP) value-based payment programs: Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).
SIR often submits comment letters to federal agencies, CMS, and insurance carriers that specifically address interventional radiology treatments. The following comment letters are available:
Within the last year, there have been several inquiries, from membership, regarding claim denials from Medicare contractors and private payers. SIR’s Economics Committee and Practice Development Committee devised an in-depth analysis that determined that SIR needed to strengthen its existing relationship with different carriers and their respective stakeholders. The first step in this systematic approach required a clear understanding of the core issues pertaining to claim denials or delayed reimbursements for interventional radiology procedures. The practice development committee designed the Carrier Advocacy Form, which allows all members to submit denial letters from all payers, including Medicare contractors and private carriers.
The SIR coding and reimbursement subcommittee sent several carrier-advocacy letters on behalf of our membership to advocate for appropriate reimbursement of specific IR procedures properly.
Coverage letter templates
SIR has found that sometimes carriers deny reimbursement to the physician or the patient for specific interventional radiology treatments. The society has developed several examples of common coverage request letters.
For more information on health policy, coding, and reimbursement, please contact the economics team.
Improper specialty designator for IR could impact future reimbursement
Is your practice using the right specialty code to properly capture your work as an interventional radiologist? In the Medicare PECOS system, interventional radiology has its own Medicare specialty code—Code 94. However, many radiology groups continue to use the diagnostic radiology identifier—Code 30—for IRs. This imprecise specialty code could negatively impact IRs as the federal government shifts to the new payment systems mandated by the 2015 Medicare Access and CHIP Reauthorization Act (MACRA).
SIR members should work with their administrators to ensure that your CMS 855 forms and PECOS enrollment are coded as Specialty 94 to ensure accurate quality reporting and payment. See the PECOS for Physicians and Non-Physician Practitioners Fact Sheet — Revised
SIR designed the E/M toolkit to help its members with proper coding and billing of evaluation and management services. There are many more coding and reimbursement resources within the health policy page.
Medicare established a national definition of a global surgical package to ensure that Medicare Administrative Contractors (MACs) make payments for the same services consistently across all jurisdictions. SIR has prepared references to assist physicians and administrators with common global periods for codes frequently reported by interventional radiologists.Learn more