Below is a one-page Spreadsheet for establishing and obtaining reasonable reimbursement for an Office-based-surgical suite, WALANT and/or In-Office Endoscopic Carpal Tunnel Release. Last update: JAN 2022.
- This checklist is to help surgeons who perform endoscopic carpal tunnel release in the office setting (POS=11 / office) negotiate optimal reimbursement. Related terms include WALANT and Office-Based Surgery (OBS).
- Getting paid for your Office-Based Surgical Suite (OBSS) “overhead.”
- Endoscopic Carpal Tunnel Release (ECTR), CPT code 29848, has a status indicator of “NA” in the “Non-Facility NA INDICATOR” field in the 2022 Medicare PFSRVU database.
- Negotiating fair NON-FAC PE expense reimbursement for ECTR when performed in an (OBSS) (as opposed to a facility (ASC, HOPD or hopsital). Otherwise, you are losing money.
- See the complete List in the Guidebook (also the Step-by-Step SS). There are many.
- Download the Decision-Tree Graphic and Spreadsheet from the IOECTR.com website.
- The practice “overhead” for the office surgical suite. Medicare has facility (ASC, HOPD, hospital) PE (FAC PE_ and non-facility (office) PE (NON-FAC PE). PE includes these six components: (direct expenses): clinical staff time, the equipment, supplies; (indirect expenses): admin. staff, building space, and office supplies.
- To help with your reimbursement negotiations every clinic should spend some time calculating their overhead costs using the six components above. Focus on direct expenses.
- The best (and easist) negotiating strategy is focusing on total savings to the insurance company for the OBSS versus the ASC, HOPD, or hospital. Ask for 80% of the facility rate.
- In the Guidebook we cover numerous negotiating tactics and how to use leverage.
- Setting up an Office-Based Surgery Suite
- This section covers all the other issues related to establishing an office-based ECTR practice. All the concepts apply to any In-Office procedure with zero Site-of-Service-Differential (SOSD.)
- This issue is related to anesthesia level and comorbidities.
- Use research to support the benefits and safety of WALANT/OBS.
- Most registration rules revolve around the level of anesthesia or surgery class.
- As of this writing the following states (SC, KS, DE, AL, AZ, NY, TX, and DC) require registration or accreditation for an OBSS. Rules change often (and some are ambiguous) so be sure to confirm your current state regulations and consult with a healthcare attorney. For the others it’s either not required or there is no information on OBS.
- Consult with your state medical board, professional association, and local zoning agencies.
- The guidebook (and step-by-step SS) list over a dozen benefits to the patient, the carrier, and the provider regarding office-based surgery.
- Wide-Awake Local Anesthesia, No Tourniquet. While WALANT can be performed in an Ambulatory Surgery Center, it is often part of an OBS surgery (instead of general anesthesia).
- This is a separate document. Use whatever feels most comfortable.
- Prepare an list of what you will need for your OBS suite that would typically be provided by and billed by the facility (ASC, HOPD, hospital). This includes supplies, the disposable blade and video monitor.
- Contingency plan in the event of an adverse effect. Hospital priviledges.
- Resuscitation plan and CPR training for staff.
- Work up a flowchart from initial scheduling to post-op visits.
- Create patient demand for your OBSS; create a flyer; advertise on your website.
- This refers mostly to 90-day procedures that are typically performed in a facility: ASC, HOPD, or hospital. It does not apply to 10-day minor procedures commonly performed in the office. The trend/movement is also called In-Office Surgery.
- On the www.IOECTR.COM website is a list of 97 orthopedic procedures that lend themselves to WALANT/OBS and have an SOSD of zero and would require contract negotiation for OBS overhead reimbursement.
- Please provide us with any feedback on negotiations during this process–good and bad.
Please use the Contact Form for comments.
- Jeffrey Restuccio