Bob,

I still remain uncertain as to your point specifically regarding 93325 but,
obviously, do share your concern regarding reimbursement . However, I am
concerned that some of your quotes of Bill Sarraille's comments may not have
been technically accurate. You are correct that I have been on several
conference calls with Bill and representatives of the Lewin Group. However,
at no point did I hear the Lewin Group acknowledge that "a mistake was made
in calculating the RVU's for noninvasive vascular." They seemed receptive
to the concept that reimbursement for noninvasive vascular testing may not
completely cover practice expense based on an excellent presentation by Bob
Zwolak that reviewed data from his institution. They also acknowledged that
the original calculation of indirect expense for the TC PE RVUs (never
implemented) was flawed by including physician work as a factor (of which
there is zero in TC procedures), but HCFA also recognized this and remedied
(at least temporarily) the problem with the creation of the zero-work pool.
However, this was not an error in the calculation (although an ill-advised
piece of the formula as far as TC procedures are concerned) and I would be
surprised to learn (1) that the Lewin Group believed that an error in
calculation occurred or that (2) Bill actually said that an error in
calculation occurred (he certainly has not in my presence).

With regard to APCs, this is a completely separate and unrelated issue.
With regard to your quote of Bill noting that HCFA believes "echo was more
difficult and they were not going to change the APC for vascular." I heard
a similar comment from a single individual; but that persons opinion did
not determine APC reimbursement. While I was present for the comment, and
disagree with the opinion, it is of absolutely no significance to the amount
reimbursed for noninvasive vascular studies. It is true that HCFA did not
accept our multispecialty societies recommendations for regrouping of the
CPT codes into APCs. But this has virtually nothing to do with any specific
procedure and, in my opinion, a lot more to do with limited resources and
time.

Are there problems with reimbursement? Sure. Is disaster imminent? Not if
you're surviving today. Could there be a catastrophe at some point in the
future? Sure. Are there, and will there continue to be problems with
reimbursement? Yes. Have some providers gone out of business due to
decreasing reimbursement? Yes.

What can be done to ensure adequate and equitable reimbursement? Be
knowledgeable regarding the topics/issues and support efforts, e.g., by SVS,
SVT, SDMS, AAN, ASN, etc., to achieve adequate representation on issues
critical to vascular technology (SVT & SDMS just picked up the tab for Anne
& I to attend almost a week of PEAC & RUC meetings simply because it is
important to reimbursement ... SVT, SDMS, SVS & ASN all are working with the
Lewin Group, and the list could go on).

What does this have to do with 93325? I have no idea.

*************************************************
Franklin W. West
PVI
18702 North Creek Parkway, Suite 212
Bothell, Washington 98011
425.398.7774 (voice)
425.486.8976 (fax)
[log in to unmask]
*************************************************

-----Original Message-----
From: [log in to unmask] [mailto:[log in to unmask]]On
Behalf Of Robert T. Kane
Sent: Thursday, February 08, 2001 5:57 AM
To: [log in to unmask]
Subject: Re: 93325

Frank,
Sorry I was in a bit of a hurry yesterday. You are correct my point does go
a little bit further. As our reimbursements decrease (see APC reductions to
2006 for coinsurance) I feel it is imperative to assail the Gatekeepers of
the Medicare Program from every legal option so we are not put out of
existence. I genuinely feel that left on their we would be obliterated by
other specialty groups. Our specialty is very small in comparison to
Radiology, Cardiology and the rest of the budget. As you, above anyone else
would know, if not for some Herculean efforts by you and Dale Asplund we
could have been buried already. I am seeing signs of eminent peril again. As
I understand from Bill Sarraille the Lewin Group has discovered, with your
and Dr. Zwolak's help, that they have admitted a mistake was made in
calculating the RVU's for noninvasive vascular. It was his opinion to me
that even though they saw an error they were not going to do very much to
fix it. Correspondingly when the APC's were first published and the inequity
with echocardiolgraphy was discussed (again this was related to me by Bill)
the HCFA response was that echo was more difficult and they were not going
to change the APC for vascular. As you know we have also lost some codes to
bundling.
As I understand it you participated in some of these meetings, so you would
know better than I if my fears are warranted. Nevertheless, I have this
really bad feeling that unless some sort of movement is instituted we will
find ourselves in jeopardy. As you are well aware if I have to take this
fight on myself I will, but I do miss you.
Robert T Kane
Phoenix Cardiovascular
Doylestown PA
----- Original Message -----
From: "Franklin W. West" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Monday, February 05, 2001 6:11 PM
Subject: 93325


> Bob,
>
> I'm uncertain regarding your point. You are correct in noting the current
> definition of 93325 is specific to echocardiography and you are correct in
> noting that CPT is in no way limited by the specialty of the provider (in
> fact, you may have been present at the meeting where a HCFA representative
> noted that any psychiatrist would be paid for the performance of cardiac
> transplant under the program - medical licensure being unlimited and a
> states rights issue). I don't believe that I suggested anything that
would
> violate either of these facts.
>
> However, given the current definition of 93325 is specific to
> echocardiography, the use of this code in other than cardiac evaluations
> would appear to be inappropriate in my opinion. I understand that this
was
> historically not the case, but it has been since 1/1/99. Personally, my
> admittedly low risk-tolerance level would not allow my use of this code to
> describe what I do when performing non-cardiac duplex scanning and I would
> find it analogous to billing for 93307 and/or 93320 (also echocardiography
> CPT codes) on non-cardiac cases. That is, I would not care to be in a
> position of having to defend to an Assistant US Attorney the use of
cardiac
> ultrasound CPT codes when not used to evaluate the heart. Somehow, the
"but
> they've got a code" argument seems more than a little weak, and not
material
> to the point. But then, that may not have been your point ...
>
> *************************************************
> Franklin W. West
> [log in to unmask]
> *************************************************
>
> -----Original Message-----
> Sent: Saturday, February 03, 2001 10:54 AM
> Subject: Re: venous insufficiency
>
> Frank,
> As you have mentioned in your communication CCI does not bundle color flow
> and our vascular duplex scans anymore. The new CPT code definition is
> Doppler echocardiography color flow velocity mapping (List separately in
> addition to codes for echocardiography). Some would get the impression
that
> you could not bill this code with a duplex vascular study. However, if you
> read the Instructions for Use of CPT paragraph 2 " It is important to
> recognize that the listing of a service or procedure and its code number
in
> a specific section of this book does not restrict its use to a specific
> specialty group. Any procedure or service in any section of this book may
be
> used to designate the services rendered by any qualified physician."
> Robert T Kane
> Phoenix Cardiovascular
> Doylestown PA
> ----- Original Message -----
> Sent: Friday, February 02, 2001 9:08 AM
> Subject: Re: venous insufficiency
>
<snip>