REGULATORY REVIEW


rent Procedural Terminology (CPT) and other invasive procedures such as percutaneous transluminal angio- plasty and cardiac catheterization. They include minimally invasive pro- cedures involving biopsies or place- ment of probes or catheters requiring the entry into a body cavity through a needle or trocar. They do not include use of instruments such as otoscopes for examinations or very minor proce- dures such as drawing blood.” ASCA also asserted in its comments that Medicare’s State Operations Manual: Appendix L adopts a similarly broad definition of “surgical procedures,” which CMS adopted from the Amer- ican College of Surgeons. ASCA, therefore, recommended that CMS revise the definition of surgical pro- cedure to better accommodate exist- ing procedures and procedures made available through technical advances that we have not yet considered. In the 2018 proposed rule, CMS sug- gested that the CPT surgical range of codes may be better used “as a guide rather than a requirement.” ASCA strongly supported this approach, as a reliance on the CPT definition resulted in some procedures being included on the covered procedures list while other, very similar procedures, remained excluded. For example, many cardiac catheteriza- tion procedures that allow for endovas- cular diagnosis and treatment of cardiac vessel conditions were excluded, while similar endovascular procedures, includ- ing the stenting of arteries performed on peripheral blood vessels, were permit- ted. We proposed 38 cardiology codes for addition to the ASC-CPL, arguing that the services proposed would create a seamless site of service for diagno- sis and treatment of cardiac conditions consistent with the care many commer- cially insured patients receive, and for which CMS reimbursed HOPDs but not ASCs. ASCA strongly encouraged CMS to move forward as quickly as possible with an expanded definition for surgical procedures to make these services avail-


CODES MIGRATION


Over the years, ASCA requested the cardiology codes below to be added to the ASC Covered-Procedures List (ASC-CPL). The years in the parentheses show when a code was added to the ASC-CPL. Inclusion on the ASC-CPL does not guarantee separate reimbursement; many of these codes are packaged and not separately payable.


Cardiac Diagnostic


Catheterization—Catheter Placement with Angiography


93451 (2019) 93452 (2019) 93453 (2019) 93454 (2019) 93455 (2019) 93456 (2019) 93457 (2019) 93458 (2019) 93459 (2019) 93460 (2019) 93461 (2019) 93462 (2019) 93463


93530 93531 93563 93564 93565


93566 (2019) 93567 (2019)


93568 (2019) 93571 (2019) 93572 (2019)


able to Medicare beneficiaries in the ASC setting.


While CMS simply thanked com- menters for their input and did not final- ize any changes to the definition of sur- gery, this dialogue was critical to laying the groundwork for 2019 rulemaking.


2019 Rulemaking Finally, in 2018, CMS formally pro- posed to revise its definition of surgery for CY 2019 to include certain “sur- gery-like” procedures that are assigned


codes outside the CPT surgical range. In the 2019 proposed rule, CMS rec- ognized that there are “services that do not directly crosswalk and are not clin- ically similar to procedures in the CPT surgical range, but that nonetheless may be appropriate to include as cov- ered surgical procedures payable when furnished in the ASC setting.” Strict adherence to the CPT surgical code groupings does not properly account for advances in treatment and “the dynamic nature of ambulatory surgery


ASC FOCUS MARCH 2021 | ascfocus.org 21


Cardiac Interventions—Catheter Placement with Angiography


92920 (2020) 92921 (2020) 92928 (2020) 92929 (2020) 92937 92938 92973 92978 92979


C9600 (2020) C9601 (2020) C9604 (2021) C9605 (2021)


Other Cardiology Procedures 93312 93313 93315 93316 92960


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