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As long as we are on the subject of who can and who cannot perform physiologic ultrasound tests, here is another question I submitted Re: Podiatrists. This information was sent on November 22, 2011

Dear Ms. Lawrenz,

 
I have podiatrists ask if they are able to perform and bill Medicare for the following procedure codes in their offices when performed by a Registered Vascular Tech.
I have podiatrists ask if they are able to perform and bill Medicare for the following procedure codes in their offices when performed by a Registered Vascular Tech.
 
performing and/or interpreting diagnostic tests for procedure codes 93922-TC, 93922-26; 93923-TC, 93923-26, 93924-TC, 93924-26, 93965-TC, and 93965-26.

performing and/or interpreting diagnostic tests for procedure codes 93922-TC, 93922-26; 93923-TC, 93923-26, 93924-TC, 93924-26, 93965-TC, and 93965-26.

Answer: 

Reference Number: 53718

Dear Mr. Ross,

Thank you for the inquiry you sent to Wisconsin Physicians Service (WPS) Medicare regarding podiatrists performing peripheral arterial studies (procedure codes 93922-TC, 93922-26; 93923-TC, 93923-26, 93924-TC, 93924-26) and peripheral venous examinations (procedure codes 93965-TC, 93965-26) in the office setting. According to your inquiry, a Registered Vascular Technician performs the technical component of these diagnostic services.

As you requested, I am writing to confirm the information we discussed during our telephone conversation on November 22, 2011. The December 2009 edition of the Communiqué has an article titled “Procedure Codes Payable for Podiatrists.” This article includes a list of procedure codes the WPS Medicare medical director staff approved for reimbursement when billed by podiatrists. The only procedure code contained within the list of procedure codes referenced above was procedure code 93922. WPS Medicare does not permit payment to a podiatrist for procedure codes 93923-TC, 93923-26, 93924-TC, 93924-26, 93965-TC, 93965-26. You may access this edition of the Communiqué on the following WPS Medicare website:

http://www.wpsmedicare.com/part_b/publications/communique/archived/_files/1209comm.pdf

For more information on performing peripheral arterial studies or peripheral venous examinations, please refer to the WPS Medicare Local Coverage Determination L28586, “Noninvasive Vascular Testing (N.I.V.T.),” on the following WPS Medicare website: 

For more information on performing peripheral arterial studies or peripheral venous examinations, please refer to the WPS Medicare Local Coverage Determination L28586, “Noninvasive Vascular Testing (N.I.V.T.),” on the following WPS Medicare website:

http://www.wpsmedicare.com/part_b/policy/active/local/l28586_cv033.shtml

It was nice speaking with you, Mr. Ross, about your concerns. I hope this information is consistent with your needs. If you need additional assistance from WPS Medicare regarding this matter, please include the reference number above in any correspondence. If immediate assistance is needed, you may reach our Provider Contact Center by calling 866-234-7331

It was nice speaking with you, Mr. Ross, about your concerns. I hope this information is consistent with your needs. If you need additional assistance from WPS Medicare regarding this matter, please include the reference number above in any correspondence. If immediate assistance is needed, you may reach our Provider Contact Center by calling 866-234-7331.

Sincerely,

Barbara Lawrenz
Provider Relations Research Specialist
WPS Medicare

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Sincerely,

Barbara Lawrenz

Provider Relations Research Specialist

WPS Medicare

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From:        "[log in to unmask]" <[log in to unmask]>

To:        [log in to unmask]

Cc:        "bobross" <[log in to unmask]>

Date:        11/05/2011 10:24 PM

Subject:        PROCEDURE CODES PAYABLE FOR PODIATRISTS. Attn: Barbara Lawrenz



This information was sent on November 22, 2011.  I would suggest you contact your CMS Medicare representative and update the information if you are in questions. 

Even if a Podiatrist has a registered technologist perform an ultrasound code above 93922, they are not allowed to bill CMS Medicare for the procedure. They are limited to billing for the 93922 only.

Final advise: do not rely on fellow colleagues to answer medical billing questions. Go directly to the billing insurance company and ask your questions. In this case: CMS Medicare. Your CMS representatives can be your best friends.

Sincerely,

Robert R. Ross, PA-C
Michigan 

CONFIDENTIALITY NOTICE: This email contains information from the sender that may be CONFIDENTIAL, LEGALLY PRIVILEGED, PROPRIETARY or otherwise protected from disclosure. This email is intended for use only by the person or entity to whom it is addressed. If you are not the intended recipient, any use, disclosure, copying, distribution, printing, or any action taken in reliance on the contents of this email, is strictly prohibited. If you received this email in error, please contact the sending party by reply email and/or delete the email from your computer system and shred any paper copies.


On Nov 7, 2020, at 7:44 AM, Robert Ross <[log in to unmask]> wrote:

Here is what a WPS Medicare Representative advised me in 2010 when I asked the question about a Medical Assistant performing a physiologic test and the practitioner billing for the exam.

Dear Mr. Ross,


Thank you for the inquiry you sent to Wisconsin Physicians Service (WPS) Medicare regarding Local Coverage Determination (LCD) L28586 “Noninvasive Vascular Testing (N.I.V.T.).”

As you requested during our telephone conversation on June 17, 2010, I am responding in writing to your inquiry. I forwarded your question to a member of our Medical Policy professional staff for assistance with answering your question. The Medical Policy staff member provided the following response. For the sake of clarity, I am restating your question.

If a medical assistant or anyone else not meeting the qualifications of a certified vascular technician (VT) performs the technical component in the office setting of the Current Procedural Terminology (CPT) codes 93922, 93923, 93924, 93965, and the physician bills WPS Medicare, would this be considered a fraudulent claim?

Medicare would consider the above services as not medically necessary.  While we would not necessarily know on a prepayment basis that the service was being provided by an unqualified person, Medicare could look at this on a post-payment basis, and Medicare could ask the provider to refund the money he or she received. This could be done by the local carrier or the Recovery Audit Contractor (RAC). The whole purpose of requiring certification is that Medicare considers reimbursement for quality images that will contribute to a correct diagnosis and treatment of the patient.

You may access the above-referenced LCD on the following WPS Medicare Website:


I hope this information is helpful. If you need additional assistance from WPS Medicare regarding this matter, please include the reference number below in any correspondence. If immediate assistance is needed, you may reach our Provider Contact Center by calling 866-234-7331.

Sincerely,

Barbara Lawrenz
Provider Relations Research Specialist
WPS Medicare 

This information was sent on 6/17/10. I would suggest you contact your CMS representative and update the information if you are in questions. 

We have never allowed Medical Assistants to perform physiologic tests: 93922; 93923;93924;93965.

Sincerely,

Robert R. Ross, PA-C
Michigan

On Nov 7, 2020, at 7:19 AM, Alessandro Nardone <[log in to unmask]> wrote:

And thank everyone for the feedback

On Fri, Nov 6, 2020 at 10:07 AM Alessandro Nardone <[log in to unmask]> wrote:
Hi All

Does anyone have or know of any position papers on training MA’s or other non sonographer personnel on performing ABI studies? It would be Very helpful if you would let me know. I did read a position paper on training fellows and doctors early in education but not what I was looking for. 

Thank you
Alessandro (Sandy) Nardone RVT, RVS
Northwell Health Western Region





--
Alessandro (Sandy) Nardone RVT,RVS, RCS
Practice Coordinator Technical Imaging/Technical Director
Northwell Physician Partners- Cardiology Western Region
Cell: 516-382-1476



--
Alessandro (Sandy) Nardone RVT,RVS, RCS
Practice Coordinator Technical Imaging/Technical Director
Northwell Physician Partners- Cardiology Western Region
Cell: 516-382-1476

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