CMS Interventional Cardiology Code to Take Effect in 2015

August 28, 2014—The Centers for Medicare & Medicaid Services (CMS) issued a “Medicare Learning Network” bulletin (MLN Matters) regarding the new CMS physician specialty code for interventional cardiology—“C3”—to become effective on January 1, 2015 (implementation date: January 5, 2015).

CMS advises all relevant parties to be sure that their billing staffs are aware of the changes involved in this action. It also encourages readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents. The agency stressed that the information provided in the bulletin is only intended to be a general summary and is not intended to take the place of either the written law or regulations. 

CMS’s MLN Matters article is intended for physicians, nonphysician practitioners, and suppliers submitting claims to Medicare Administrative Contractors (MACs) for services to Medicare beneficiaries.     

The MLN Matters bulletin summarizes the CMS change request (CR) action, CR 8812, which was made available online in two transmittals on August 22. CR 8812 establishes “C3” as the new interventional cardiology code and details the parties responsible for knowing and implementing these provisions, including MACs, shared-system maintainers, contractors using Contractor Reporting of Operational and Workload Data (CROWD) forms, and providers using Provider Enrollment Chain of Ownership System (PECOS) forms.

As detailed in the first transmittal (#3048) of CR 8812 related to Medicare Claims Processing, the provisions for the new interventional cardiology designation are:
•    (8812 – .04.1) Contractors shall make all necessary changes to recognize and use the new physician specialty code C3 as a valid primary specialty code for interventional cardiology. 
•    (8812 – 04.2) Contractors shall accept specialty code interventional cardiology- C3 as a secondary code. 
•    (8812 – 04.3) The PECOS shall make the necessary changes to recognize and use the new physician specialty code C3 as a valid specialty code for interventional cardiology.     

In the second transmittal (#238) related to Medicare Financial Management, the new provisions are:

•    (8812 – 06.1) Contractors shall include physician specialty code C3 (interventional cardiology) with their submission for CROWD Form "F" (Participating Physician/Supplier Report), in accordance with Publication 100-06, chapter 6. 

In addition to the interventional cardiology designation, CR 8812 provides changes to the description of specialty code 62 and updates the names associated to specialty codes 88 and 95: the word “Clinical” is removed from the description of specialty code 62 for “Psychologist (Billing Independently)” and changes the description of specialty code 88 to “Unknown Provider” and specialty code 95 to “Unknown Supplier.” CR 8812 also establishes a nonphysician specialty code “C4” for “Restricted Use.”

The new specialty designation was requested by the Society for Cardiovascular Angiography and Interventions (SCAI), which announced on May 29 that CMS granted the request. 

In the society’s Summer 2014 newsletter, SCAI offered guidance to its members on the next steps, which include CMS’s MACs being required to adapt their systems to accept the new interventional cardiology designation code. Physicians to be recognized by CMS as interventional cardiologists will need to resubmit their participating provider form to their MAC. SCAI stated it will post complete information on its website, www.SCAI.org, as soon as these forms are available. Society members may contact Wayne Powell, SCAI’s Senior Director for Advocacy and Government Relations, to sign up for updates on these developments or for assistance or clarification by email at wpowell@SCAI.org or by phone at (202) 741-9869.

In the newsletter, Mr. Powell advised members, “Please do not be intimidated by the length of the form. Most members should already have a copy of this form on file and will simply need to change the specialty section.” Mr. Powell also noted, “During our ongoing analysis of the healthcare landscape, we confirmed that being recognized as a separate and distinct specialty has been an important milestone for many fields. It also increases the specialty’s prominence and enhances its credibility.” 

Peter L. Duffy, MD, who is SCAI Secretary and Advocacy Committee Chair, added, “SCAI filed for a dedicated physician specialty code in 2013, upon confirming with government officials and other analysts that interventional cardiology has evolved to a point where many of the patients we treat and the treatments that we can offer are significantly different from those of general cardiology and other cardiovascular subspecialties. Having our own designation will help us to ensure that our concerns and priorities will receive sufficient consideration and will not be lumped in with those of others.”

In the newsletter, SCAI noted that it expects that payers will soon be calculating the costs of procedures performed by interventional cardiologists and comparing those costs to those for treatments provided by noninvasive cardiologists, potentially leading to unfair, “apples-to-oranges” comparisons of practice patterns and erroneous reporting of members as outliers. Having this specialty designation is especially important in today’s health care environment, when CMS and other payers are profiling providers based on the costs of the services they deliver to beneficiaries, stated SCAI.