That are currently assigned as \u201cfacility-only.\u201d These do not have a Site of Service Differential.<\/p>\n\n\n\n
My name is Jeffrey Restuccio, CPC, COC, I am a reimbursement expert and I\u2019m working on a long-term project with the goal of obtaining appropriate office overhead reimbursement (non-facility physician expense RVU\u2019s or a \u201cfacility fee\u201d) for surgeries that currently do not have a Site of Service differential in the Medicare 2020 PFSRVU database. Technically, anything reported with Place of Service (POS) of 11 is an office procedure and there is no separate facility fees paid for numerous procedures including endoscopic carpal tunnel release. The office overhead is included in the Site of Service Differential as indicated by the difference in the Non-Facility Physician Expense RVU\u2019s.<\/p>\n\n\n\n
My research would apply to any office-based surgery where the procedure would either be denied as \u201cWrong Place of Service\u201d or the Facility Professional Fee RVU\u2019s would be paid for an office-based surgery\u2014and there would be no facility reimbursement. Numerous 90-day global procedures are designated as \u201cfacility-only.\u201d That includes cataract surgery, foot surgeries and soft-tissue endoscopic surgeries.<\/p>\n\n\n\n
The information I\u2019m collecting will be made available for free. It will be of great benefit to Providers, patients, and insurance companies if common, quick, low-risk, and minimally invasive procedures could be performed in an office setting. Some patients benefit from being awake and able to respond to commands during the procedure (known as WALANT [Wide Awake Local Anesthetic No Tourniquet)]).<\/p>\n\n\n\n
While there is information on Office-Based Surgery (OBS) and WALANT there is virtually no information on how best to get appropriate overhead reimbursement where there is no Site of Service Differential. Until Medicare adds a non-facility Physician Expense, the only way is for the doctor or clinic to negotiate with each carrier for an appropriate \u201cfacility fee.\u201d Note that one cannot charge a separate facility fee for POS=office. There is some discussion concerning setting up a separate tax ID and billing companies using schemes to get paid but most of those are fraudulent and could cause legal problems.<\/p>\n\n\n\n
My current challenge is determining who and how the Site of Service Differential is calculated and why some codes are deemed as facility-only and others are not. Generally procedures with less risk, take less time, and require fewer resources can be performed either in the office or the ASC, outpatient hospital or hospital, depending on the need for resources in case there are complications (it\u2019s mostly linked to the anesthesia required and safety of the patient).<\/p>\n\n\n\n
However, research into the 2020 Medicare PFSRVU database shows that there are numerous exceptions between 10-day global and 90-day global procedures and there is a wide variance between Work RVU\u2019s, Total RVU\u2019s, and Facility Physician Expense RVU\u2019s and whether there is a Site of Service Differential or not. In layman\u2019s terms: it\u2019s all over the place and there are numerous unexplained inconsistencies in the data.<\/p>\n\n\n\n
My current assumption is that professional societies lobby for appropriate facility fees and there is team at Medicare that determines what resources (overhead) is appropriate. I would love to see how the calculations are made, what information is used and if there is a consistent method for determining the facility versus non-facility RVU\u2019s. Also, I believe that some codes just fall through the cracks. Some should be designated as office or facility, some should be changed from 90-day to 10-day. I am currently working to find the correct people.<\/p>\n\n\n\n
In regard to IOECTR (In-office Endoscopic Carpal Tunnel Release) there are two strategies:<\/p>\n\n\n\n
If you have any feedback that will help our effort please e-mail using the contact form or call me at (901) 517-1705. I look forward to working with you.<\/p>\n\n\n\n
Jeffrey Restuccio, CPC, COC, MBA<\/p>\n","protected":false},"excerpt":{"rendered":"
That are currently assigned as \u201cfacility-only.\u201d These do not have a Site of Service Differential. My name is Jeffrey Restuccio, CPC, COC, I am a reimbursement expert and I\u2019m working on a long-term project with the goal of obtaining appropriate office overhead reimbursement (non-facility physician expense RVU\u2019s or a \u201cfacility… Continue reading