SIR and its members are dedicated to improving public health through pioneering advances in minimally invasive, image-guided therapies.
On May 1, 2023, the SIR submitted a comment letters to Aetna, AIM, Cohere, Evicore, HCSC, and Humana requesting a change in coverage policy for percutaneous vertebral augmentation (PVA) for osteoporotic vertebral compression fracture to mirror the current Medicare coverage determination. The medical necessity in these policies are limiting surgical procedures to fractures over six weeks old and should be revised/eliminated as these requirements have the potential to negatively impact patient outcomes and providers’ ability to deliver evidence-based, appropriate spinal care to all patients. This letter was supported by eleven medical specialty societies.
In April 2023, SIR signed on to a comment letter to Cigna expressing concerns with its forthcoming policy that will require the submission of office notes with all claims, including evaluation and management services and modifier 25, when a minor procedure is billed.
Cigna’s modifier 25 policy effective 5/25/23
In March 2023, SIR signed on to a comment letter providing feedback on the Advancing Interoperability and Improving Prior Authorization proposed rule which was submitted to Centers for Medicare and Medicaid Services (CMS) by the Alliance of Specialty Medicine. This proposed rule would place new requirements on Medicare Advantage organizations, state Medicaid fee-for-service (FFS) programs, state Children's Health Insurance Program (CHIP) FFS programs, Medicaid managed care plans, CHIP managed care entities, and Qualified Health Plan issuers on the federally facilitated exchanges to improve the electronic exchange of healthcare data and streamline processes related to prior authorization, while continuing CMS' drive toward interoperability in the healthcare market. To learn more about this proposed rule, click here.
In March 2023, SIR signed on to a comment letter opposing HB 2168 Oklahoma Interventional Pain Management and Treatment Act. The bill proposes a new definition of “interventional pain management” as healthcare delivery, as opposed to the practice of medicine, and would expand opportunities for certified registered nurse anesthetists (CRNAs) to perform interventional pain procedures. CRNAs are valuable members of the healthcare team; however, their training does not provide the expertise required to perform interventional pain procedures. To learn more about this bill, please click here.
In February 2023, several Medicare Administrative Contractors (MACs) posted a final local coverage determination for sacroiliac joint (SIJ) interventions and procedures. The proposed policy deems SIJ denervation (also called radiofrequency ablation, or RFA) as not reasonable and necessary. SIR respectfully disagrees and submitted comments in October 2022 during the open comment period for this proposal. In addition, SIR provided ample clinical literature regarding the role of RFA during the proposed comment period. SIR has signed onto a multispecialty letter sent to these same MACs: Palmetto, Noridian, Wisconsin Physicians Service, National Government Services, and Celerian Group Company in March 2023. These policies will prevent patient access to a highly effective opiate alternative treatment option if these policies go into effect.
In February 2023, SIR submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) for the reconsideration of national coverage determination (NCD) 20.7 for percutaneous transluminal angioplasty (PTA) of the carotid artery concurrent with stenting.
Since the prior NCD, the SIR has monitored developments in the literature and additional outcomes have been published that support equipoise between CEA and CAS, thus supporting broader patient selection for CAS reimbursement. Based on this expanded body of clinical evidence, SIR supports updating NCD 20.7 to broaden Medicare beneficiary access to PTA and CAS.
In January 2023, representatives from the Spine Intervention Society's Standards Division and Evidence Analysis Committee developed the following best practice recommendations for the performance of interventional pain procedures in the setting of a local anesthetic shortage. SIR, along with many other specialty societies, endorsed the following best practice recommendations and statements for the performance of intra-articular, extra-articular, paraspinal and epidural injections in the setting of a local anesthetic shortage.
SIR became aware of carriers denying coverage for SIRT/TARE of metastatic colorectal cancer to the liver. Our Carrier advocacy workgroup has developed an evidence-based letter to help members overturn these denials in Mar 2023. You can find the letter by clicking here, all you need to do is add your information to the letter and send it to the carrier that has denied your services.
As SIR becomes aware of carriers denying coverage for IR procedures, our carrier advocacy workgroup develops evidence-based coverage letters to help our members overturn these denials. The letters are reviewed and updated with the most current evidence. Our Carrier advocacy workgroup updated the prostatic artery embolization (PAE) letter for benign prostatic hyperplasia (BPH) treatments in Mar 2023. Please click here to be connected to the IR Business Center.
As SIR becomes aware of carriers denying coverage for IR procedures, our carrier advocacy workgroup develops evidence-based coverage letters to help our members overturn these denials. The letters are reviewed and updated with the most current evidence. Our Carrier advocacy workgroup updated the ovarian and internal iliac vein embolization for the treatment of pelvic venous disorder (pelvic congestion syndrome) in Mar 2023. Please click here to be connected to the IR Business Center.
Within the last year, there have been several inquiries, from members, 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.
Include the payer policy denial with your submission and remove all patient information.
The SIR carrier advocacy team found that 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 to help overturn carrier policy, denied authorizations, and denied claims.
The Center for Medicare and Medicaid Services (CMS) allows a comment period on proposed national coverage determinations. On behave of our SIR members, the carrier advocacy team creates evidence base comment letters to advocate for appropriate reimbursement of specific IR procedures properly.
For more information on health policy, coding, and reimbursement, please contact the economics team.
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 Checklist for Individual Physician and Non-Physician Practitioners using PECOS.
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.
Learn how you are listed or for more information on health policy, coding, and reimbursement, please contact Ashley Maleki.
Send your coding questions to SIR staff. This ensures that the details of your coding question do not get lost in translation from a phone message.
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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.
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