UPCOMING MEETINGS & COURSES
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ASIPP PODCASTS
Here are some of the available ASIPP® Podcasts:
- A Discussion on Tolerance, Dependency, and PTSD with Dr. Joseph Cabaret and Dr. Kenneth Carle
- Dr. Amol Soin And The Business Side Of COVID-19
- Dr. Kevin Pho of KevinMD.com Reveals Terrific Insight And Ideas On The “New Norm” After The COVID-19
- Andrea Trescot, MD Takes On The Subject Of Controlled Substance Management
- ASIPP® Pod August 2019 – Distinguished Pain Leaders Prunskis, Prunskis, and Helm Discuss Issues That Face IPM
- Miles Day Of Texas Tech Discusses Multiple Pain Management Topics
ASIPP MEMBERSHIP
Join ASIPP. Your Voice For Interventional Pain Management
First Coast and Novitas Retire Proposed LCD on Nerve Stimulators for Chronic Intractable Pain
May 5, 2023
First Coast and Novitas Retire Proposed LCD on Nerve Stimulators for Chronic Intractable Pain
After unrelenting pressure from the American Society of Interventional Pain Physicians (ASIPP), Florida Society of Interventional Pain Physicians, (FSIPP) (lead by Dr. Deborah Tracy), and other state societies, First Coast and Novitas have ruled to retire the proposed LCD, Nerve Stimulators for Chronic Intractable Pain (DL39406), related Local Coverage Article (LCA) (DA59190), Nerve Stimulators for Chronic Intractable Pain (DL39404), and Billing and Coding: Nerve Stimulators for Chronic Intractable Pain (DA59188).
- See First Coasts’ Update History: https://medicare.fcso.com/Coverage_News/0482550.asp
- See Novitas’ Update History: https://www.novitas-solutions.com/webcenter/portal/MedicareJL/pagebyid?contentId=00006151
In the correspondence from First Coast, the CMD responded, “all of the new information, along with any new evidence we reviewed specific to painful diabetic neuropathy, will be carefully considered if we decide to publish a revised proposed LCD. Any new proposed LCD will also be published for comment in accordance with CMS guidelines. If we decide to publish a new LCD on this topic, the earliest we anticipate publishing the revised LCD would be early in 2024.”
- Read FSIPP’s position statement in their letter to First Coast/Novitas here: https://asipp.org/fsipp-position-statement-scs-pns-2022/
- Read FSIPP’s follow-up letter to First Coast/Novitas here: https://asipp.org/fsipp-letter-2023/
On March 23, 2023 ASIPP sent a letter of concern to Blue Cross Blue Shield of Tennessee in regards to a proposed policy which would consider implantable peripheral nerve stimulation devices for the treatment of acute and chronic pain to be considered investigational.
- Read the BCBS of Tennessee’s proposed policy here: https://asipp.org/bcbs-tn-draft-implantable_periph_nerve_stim_pol/
- Read ASIPP’s letter to BCBS of Tennessee here: https://asipp.org/blue-cross-blue-shield-of-tennessee-003/
We will continue to lobby the remaining Medicare contractors and the national Medicare Director, Tamara Syrek Jensen on this matter as we did with First Coast.
ASIPP will keep our members updated as new information becomes available.
New Training Requirement for all DEA-Registered Practitioners on the Treatment and Management of Patients with Substance Use Disorders
April 18, 2023
On December 29, 2022, the Consolidated Appropriations Act of 2023 enacted a new one-time, eight-hour training requirement for all Drug Enforcement Administration (DEA)-registered practitioners on the treatment and management of patients with opioid or other substance use disorders (Medication Access and Training Expansion (MATE) Act). Click here to see the letter from the DEA.
Beginning on June 27, 2023, practitioners will be required to check a box on their online DEA registration form—regardless of whether a registrant is completing their initial registration application or renewing their registration—affirming that they have completed the new training requirement.
The deadline for satisfying this new training requirement is the date of a practitioner’s next scheduled DEA registration submission—regardless of whether it is an initial registration or a renewal registration—on or after June 27, 2023.
This one-time training requirement affirmation will not be a part of future registration renewals.
In response to this need, ASIPP has developed the virtual review course Controlled Substance Management Virtual Review Course: Medication Access and Training Expansion (MATE) Act. This virtual review course will be held on May 21, 2023. In addition to covering the required Curriculum to Meet MATE Act Requirements for DEA Licensing, it will also provide 10.5 AMA PRA Category 1 Credits™. Click here for the agenda. Click here to register.
Various Issues Found in Long-Term Outcomes in Use of Opioids,
Non-pharmacologic Pain Interventions, and Total Costs of Spinal Cord Stimulators Compared with Conventional Medical Therapy for Chronic Pain
March 28, 2023
Medicare Improperly Paid Physicians an Estimated $30 Million for Spinal Facet-Joint Interventions
March 22, 2023
The Office of Inspector General for the United States Department of Health and Human Services has conducted yet another audit on facet joint interventions, this is the third audit. There have been extensive audits from UPICs, SMRC, Nordian, and RAC, and MAC contractors.
In this study (click here to read), OIG looked at 120 sample sessions, with only 54 complying with Medicare requirements.
The overall estimated overpayments appear to be $29.6 million for facet joint interventions for an audit period of August 1 through October 31, 2021, with new LCDs in effect.
Obviously, there will be even more audits and there will be recoupment from multiple providers on these claims.
It is crucial that we follow appropriate algorithmic approach and utilize checklists to avoid such issues.
- A checklist for Facet Joint Interventions can be found here: https://asipp.org/checklist-for-facet-joint-interventions/
- Click here for an Algorithmic Approach to Facet Joint Interventions: https://asipp.org/wp-content/uploads/An-Algorithmic-Approach-to-Facet-Joint-Interventions.png
Controversies on the Effectiveness of Spinal Cord Stimulation Continue
March 21, 2023
Medicare Improperly Paid Physicians for Epidural Steroid Injection Sessions
March 10, 2023
The Office of Inspector General for the United States Department of Health and Human Services found that Medicare did not always pay physicians for epidural steroid injection sessions in accordance with Medicare requirements.
Read more: https://oig.hhs.gov/oas/reports/region7/72100618.asp
ASIPP’s Recent Advocacy Efforts
February 15, 2023
ASIPP has been actively addressing recent coverage issues through letter correspondence to various agencies. The issues and letters include the following:
AIM published new guidelines effective 04/09/2023. Owned by Anthem, Inc (ANTM), the AIM guidelines are utilized by multiple insurers. ASIPP has addressed the guidelines with a comment letter on the guidelines for Appropriate Use Criteria: Interventional Pain Management. Our comments were related to paravertebral facet joint injection/medial branch nerve block/neurolysis/therapeutic facet joint interventions. Click here to see letter.
We are requesting LCD reconsideration requests to all of the Medicare Contractors for the LCD covering Facet Joint Interventions for Pain Management. Click here to see letter.
ASIPP immediate past president, Amol Soin, sent a letter to Cigna on February 7 addressing their Medical Policy Update on Peripheral Nerve Block Procedures (for trigeminal and occipital neuralgia) which considering them experimental, investigational, or unproven, with an efficacy date of April 18th, 2023. In the letter, we ask that the policy update restricting the use of peripheral nerve blocks be re-evaluated and modified. We recommended that these procedures continue to be covered and we find the characterization of these procedures to be experimental or investigational to be inaccurate. Click here to see letter.
Sacroiliac Joint Injections and Procedures: A New LCD Effective 3/19/2023
February 8, 2023
CGS (L39383), Palmetto (L39402), WPS (L39475), NGS (39455), and Noridian (L39462 and L39464) jurisdictions, have issued SI joint injection policies:
Novitas and First Coast Services have not issued their policies nor have they participated in multijurisdictional committee and have not issued a policy.
You can use this algorithmic approach whenever you see your patients by utilizing these checklists for each patient prior to performing epidural steroid injections and facet joint interventions.
New AIM Guidelines Effective April 9, 2023
AIM has published new guidelines effective 04/09/2023. AIM guidelines are utilized by multiple insurers. AIM is owned by Anthem, Inc (ANTM).
Click here to find what we have presented.
Congress Passes $1.7 Trillion Omnibus Spending Package, Proposing Medicare PAYGO Physician Pay Cut of 2% Beginning in January 2023 with Continuation of 2% ACA Sequester Cuts
The important aspects of Omnibus include proposed pay cuts of 2% in 2023 for physicians, a reduction from 4.5%, and in 2024, the cuts will increase to 3.5%. The Wall Street Journal described this as the ugliest Omnibus bill ever with a 4,155 page bill that most members will never read. This bill includes multiple provisions affecting healthcare providers:
1. Reduce the physician fee schedule cut from 4.5% to 2% for 2023 and 3.5% for 2024
2. Prevents the 4% statutory pay as you go sequester for 2 years
3. Provides extension of telehealth services for 2 years
4. The worst news is that:
- There is no mention of 2% sequester cut from ACA. Consequently, the 2% sequester cut will continue. Obviously, this will result in 4% cut for physician fee schedule from 2022 (2% new cut + 2% sequester cut = 4%).
- For facilities, sequester cut of 2% will be implemented through 2023.
Sample schedules are as follows:
- Physician Fee Schedule
- Ambulatory Surgery Center Fee Schedule
- Hospital Outpatient Department Fee Schedule
To view the entire fee schedule go to the ASIPP members only website.
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Anesthesia for Pain Management Procedures: CGS Confirms the Message ASIPP has been Giving Membership
ASIPP has been working on the issues concerning anesthesia for pain management procedures for a long time.
In the September 20, 2022 CGS News Publication, “Anesthesia for Pain Management Procedures,” CGS confirms the message ASIPP has been giving our membership:
Mild sedation is acceptable for all interventional procedures. Monitored anesthesia care is acceptable for radiofrequency neurotomy procedures. Otherwise, claims billed with moderate or deep sedation, general anesthesia, or MAC during a pain management procedure, other than radiofrequency, will be denied. Note: The entire claim will be denied—not just the sedation claim.
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United Healthcare Revises Epidural Injection Policy from 3 to 4 per Year, Based on the ASIPP Recommendation
Important news! United Healthcare’s new policy reverses the previous policy with a limit of three (3) epidural injections to the ASIPP recommendation of four (4) procedures per year.
As you know, ASIPP has resolutely advocated for the change in the policy on epidural injection limits of three (3) per year through evidence-based presentations and communication. We first sent a letter on June 21, and they responded on June 27. Since then, we have continued with multiple other correspondences. Consequently, they published the new policy effective November 1, 2022, which now provides coverage for four (4) procedures.
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Alarming Payment Schedule for Physicians, ASC, and HOPD Rules
Once again, physician payment, as well as ASC and HOPD rules, are out. The most alarming is physician payment, followed by ASC and HOPD rules. The rules show reductions of 4.4% in the conversion factor even though the makeup was only 3% during last year. In addition to this, we must add, as we have been repeatedly saying, a total of 6% leading to 10.4%. With 9% inflation, we are looking for physician payment cuts of 20%.
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Onerous 10.4% Cut is Coming for Physicians, Compounded by an Escalating 9% Inflation, Equaling a 20% Cut: Act Now! Your Survival is at Stake
CMS has published the 2023 Physician Fee Schedule and it is worse than we expected. The conversion factor has been reduced by 4.4%. It will be reduced from $34.61 to $33.08, a decrease of $1.53. This will be added to the 2% sequester cut from ACA and 4% statutory PAYGO from the American Rescue Plan Act. This is equal to nearly a 20% cut when you combine this with inflation. Unless Congress acts, the total expected cuts are 10.4% from 2022, and 9.75% from 2021, starting January 2023.
We encourage every ASIPP member to join us in the effort to contact every member of Congress. You can start by contacting the Senators and Representatives of your
district. It is essential that we act soon and participate in meetings with members of our Congress, as well as start a letter campaign involving physicians, providers, nurses, staff, and most importantly, the patients.
Please see the fact sheet (FACT SHEET) and sample
letters (SAMPLE PHYSICIAN LETTER) (SAMPLE PATIENT LETTER).
Link to submit patient letters: https://www.votervoice.net/ASIPP/campaigns/96404/respond
Link to submit physician letter: https://www.votervoice.net/ASIPP/Campaigns/96405/Respond
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United Healthcare Update on Recent Publication of Medical Policy for Epidural Steroid Injections for Spinal Pain
ASIPP received a response letter from United Healthcare addressing our letter to them regarding the recent publication of medical policy for epidural steroid injections for spinal pain – Policy Number: 2022T0616D.
They are reviewing their policy and we ASIPP will continue to correspond with Untied Healthcare regarding their upcoming draft.
See our June 21 letter to United Healthcare and their June 27, 2022 response letter to us.
Additionally, on July 14 we contacted Centene on two clinical policies: Caudal or Interlaminar Epidural Steroid Injections and Selective Nerve Root Blocks and Transforaminal Epidural Steroid Injections.
An Algorithmic Approach & Checklist to
Epidural Steroid Injections
After being made aware that several physicians are being audited, we are concerned that some members are having difficulty conforming to the LCDs and medical policies. In response, ASIPP is providing you with an algorithmic approach and a checklist.
Regardless of the opinions you hold and the evidence that exists, it is crucial to follow the LCDs. Whatever is quoted in the LCD or medical policy is final and we must abide by those.
See: https://asipp.org/icd-10-codes/
Any changes you believe are warranted should be presented for consideration through a redetermination process for LCDs or medical policies for private insurers or Medicaid. They can be submitted during the next cycle of revisions.
You can use this algorithmic approach whenever you see your patients by utilizing these checklists for each patient prior to performing epidural steroid injections and facet joint interventions.
Click here for Documentation, Indications, Limitations, Utilization, and a Checklist for Epidural Steroid Injections.
An Algorithmic Approach & Checklist to
Facet Joint Interventions
The algorithmic approach describes diagnostic block procedure, as well as therapeutic interventions.
Click here for Documentation, Indications, Therapeutic Facet Joint Interventions, Limitations, and a Checklist for Facet Joint Interventions.
IMPORTANT NEWS!
Percutaneous Adhesiolysis Is Now Covered in All States
Percutaneous adhesiolysis has faced multiple issues related to coverage in the past few years. Initially, Noridian issued a noncoverage decision, followed by Palmetto issuing an experimental procedure decision.
Since then, we have incorporated into discussions on epidural LCD. While it was discussed in epidural LCD, it was not issued in the final consideration. We continued our efforts for coverage of this procedure and general consensus was that they all will be covering as any other Medicare services in the absence of a particular policy. We continue to face questions with Palmetto and Noridian.
After many years of advocacy, we have finally succeeded in getting coverage for this important procedure in all states, including all Palmetto and Noridian states in the United States.
We are very grateful to the Multijurisdictional Committee that convened considering epidural injections on 2/11/2021 for considering percutaneous adhesiolysis. We are also grateful to the Medical Directors of Palmetto and Noridian MACs for their prompt response.
Enclosed, please see the letters written to Palmetto and Noridian and the responses from Palmetto and Noridian.
Louisiana House Bill 941 is Tabled after ASIPP and LSIPP’s Opposition
The American Society of Interventional Pain Physicians (ASIPP) and Louisiana Society of Interventional Pain Physicians (LSIPP) actively opposed Louisiana HB 941 which would restrict access to minimally invasive spine procedures performed by appropriately trained interventional pain management physicians.
The bill would restrict access to care, prevent new minimally invasive techniques from being accessed in LA which are currently readily available across the country, and ultimately harm patient care by forcing patients to have much larger and more invasive procedures completed by surgical specialists who only seek to protect their financial well-being by restricting access only to themselves to complete more invasive procedures.
ASIPP, IPM, and Patient Response to the Proposed CDC Guidelines
The 2016 CDC opioid guidelines were aimed at primary care providers, but many state boards mandated them by law, resulting in tremendous needless suffering and exacerbating the illicit opioid epidemic with causation of needless deaths. These guidelines not only restrict opioid prescriptions, but also have restricted almost all interventional techniques to reduce access and sending patients to the streets for illicit opioids. With the new guidelines, these unintended consequences, including overdoses, deaths, and access limitations will continue.
The guidelines should call for a multidisciplinary approach to chronic pain that includes multiple modalities incorporating the role of interventional pain management for diagnosis and treatment.
[ HOW TO ACT ]
Good News! Telehealth Services Extended Through December 2023
Telehealth services, including telephone only services, were added as an emergency at the onset of COVID with multiple efforts from ASIPP and other organizations. However, CMS has now extended this through 2023.
Telephone CPT codes (99212 -95, 99213 -95, 99214 -95, 99441, 99442, 99443) have been eliminated from the 2022 fee schedule effective December 31, 2021. However, the public health emergency (PHD) was later extended with a new effective date through April 17, 2022.
CMS has issued a new notification that:
All telehealth services temporarily added to the telehealth services list during the PHE will remain on the list through December 31, 2023. These services include those that would have been removed as of December 31, 2021.
This is great news. Consequently, we do not have to worry about for 2 more years.
To read more about this Public Health Emergency Declaration, go to https://www.phe.gov/Preparedness/legal/Pages/phedeclaration.aspx
Thank you again for your interest in ASIPP. We will continue to update you as we obtain information on these crucial issues.
Updated Information on the Nationwide LCD Policy for Epidural Procedures for Pain Management
CGS has released its final policy for epidural steroid injections for pain management has been released. This will be effective 12/5/2021. Please check your individual MACs. Read more…
Public Health Emergency Covering Telephone Only Services Extended through January 17, 2022
The public health emergency (PHE) was set to expire on October 18, 2021. Secretary Becerra has once again renewed this PHE for a period of 90 days, which will extend the coverage for telephone only services until at least January 17, 2022. Currently, it is expected that HHS will continue to renew it declaration of the PHE every 90 days through the end of 2021 and will provide 60 days’ notice prior to ending it.
Our letter campaign is also trying to prevent cuts of 9.75% for physician payment and 6% for facility payment. To participate in the letter campaign and to read more about this issue by visiting the ASIPP Advocacy site at. https://asipp.org/advocacy/
CALL TO ACTION!
In January 2022, physician practices face the following Medicare financial hits:
1. Physician Payment Cuts
• The expiration of the congressionally enacted 3.75% temporary increase to the Medicare physician fee schedule conversion factor, which was set into place to avoid payment cuts associated with budget neutrality adjustment tied to PFS policy changes.
• The expiration of the current reprieve from the repeatedly extended 2% sequester stemming from the Budget Control Act of 2011. It appears that while Congress originally scheduled this policy to sunset in 2021, it will now continue into 2030.
• The Imposition of a 4% statutory PAYGO sequester resulting from passage of the American Rescue Plan Act, presumably extending for at least another 10 years.
2. Facility Payment Cuts
• Under the present status, it appears that ambulatory surgery centers and other facilities will be suffering with 2% cut from sequester extension and a 4% reduction with imposition of a 4% statutory PAYGO sequester resulting from passage of the Budget Control Act of 2011
3. Telephone Only Services
• CMS has eliminated coverage for telephone only services (CPT 99441-99443), effective December 20, 2021.
Link to submit patient letters through VoterVoice: https://www.votervoice.net/ASIPP/campaigns/88591/respond
Link to submit physicians and staff letters through VoterVoice: https://www.votervoice.net/ASIPP/campaigns/88596/respond
A proposed LCD on Epidural Procedures for Pain Management services was announced on June 10, 2021. This nationwide policy contains many onerous changes that will detrimentally affect patient access to care. ASIPP has written comment letters with detailed explanations of the issues and needed changes to each Medicare Contractor. Click to read more.
The Good, the Bad, and the Ugly of HOPD and ASC Proposed Rule for 2022
GOOD
Telehealth services are preserved through 2023 and evaluation management services are expanded.
BAD
Expiration of the congressionally enacted 3.75% temporary increase in Medicare physician fee schedule conversion factor, reducing the conversion factor by 3.75%.
UGLY
Addition of 6% cuts, 2% from 2011 of Obama era, and 4% from American Rescue Plan Act of 2021, totaling 6%.
UGLIER
It could get even uglier if Congress passes infrastructure bills as one unit or 2 units, which may add additional 4% or more to the cuts.
CMS Releases Proposed 2022 Physician Fee Schedule: The Good, the Bad, and the Ugly
GOOD
Telehealth services are preserved through 2023 and evaluation management services are expanded.
BAD
Expiration of the congressionally enacted 3.75% temporary increase in Medicare physician fee schedule conversion factor, reducing the conversion factor by 3.75%.
UGLY
Addition of 6% cuts, 2% from 2011 of Obama era, and 4% from American Rescue Plan Act of 2021, totaling 6%.
See Comment Letter to CMS on Proposed Physician Fee Schedule
From the beginning of the Covid-19 pandemic to all the variants, keep up to date here on all the issues related to your practice.
Click here to access ASIPP’s COVID-19 Resources. Here is a list of some of the articles found there:
1. ASIPP Draft Guidance Document on COVID-19 Vaccine and Steroids
2. Good News About Telehealth and Payroll Protection Program
Audits of Medicare Payments for Spinal Pain Management Services
Medicare Part B covers various spinal pain management services including facet joint injections, facet joint denervation sessions, lumbar epidural injections, and trigger point injections. Medicare Part B also covers sedation administered during these pain management services. We will audit whether Medicare payments for spinal pain management services billed by physicians complied with Federal requirements. Expected Issue Date (FY) 2022
Click here for more information and related articles.
ASIPP UPDATES
ASIPP is pleased to announce the publication of the Comprehensive Evidence-Based Guidelines for Epidural Interventions in the Management of Chronic Spinal Pain. In preparation of the guidelines, an extensive literature review was performed. The 210-page guidelines contains 33 figures, 48 tables, 1,345 references and has 60 authors.
In addition to the review of multiple manuscripts in reference to utilization, expenditures, anatomical and pathophysiological considerations, pharmacological and harmful effects of drugs and procedures, for evidence synthesis, we have included 47 systematic reviews and 43 RCTs covering all epidural.
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ANNOUNCEMENTS
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Doctor Finder allows you to search for an ASIPP® Member Interventional Pain Physician anywhere in America by name or by location. It’s quick and easy.
Since this malpractice insurance program officially launched in November 2018, ASIPP has signed up hundreds of providers with an average savings of 30%. This is professional liability insurance tailored to our specialty and will stand up for us and defend our practices.
Curi is a full-service advisory firm that serves physicians and their practices. Their valued advice is grounded in your priorities and elevated in your outcomes. They are driven by a deep understanding of your specific circumstances in medicine, business, and life. To read a few important points to keep in mind about the program, including discounts, administrative defense, cyber coverage, aggressive claims handling, and complimentary risk management CME activities, click here.
PainExam is proud to announce that it now offers preparation for the ABIPP Pain Management Board Exam! In addition, PainExam has now collaborated with ASIPP to offer Virtual Learning programs.
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PainCast, the pain management network, has collected years worth of information on the history and processes of the pain management specialization and transformed it into a virtual library of videos, journals, articles, podcasts, and more – all at your fingertips.
Essentials of Regenerative Medicine in Interventional Pain Management is a book to bring concise, collective, and comprehensive information to interventional pain physicians practicing regenerative medicine with its applications in managing chronic pain.
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ASIPP has formed a partnership with Henry Schein and PedsPal, a national GPO that has a successful history of negotiating better prices on medical supplies and creating value added services for the independent physician.
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ASIPP is now offering our members the benefit of a unique revenue cycle management/billing service. We have received a tremendous amount of interest in the ASIPP billing and coding program.
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