Focus on Mohs surgery
Cracking the code
Dr. Miller, who is in private practice in Yorba Linda, California, represents the American Academy of Dermatology on the AMA-CPT Advisory Committee.
By Alexander Miller, MD, August 1, 2020
Several new initiatives by the Centers for Medicare and Medicaid Services (CMS) or Medicare Administrative Contractors (MACs) may impact those who perform Mohs surgery. Let’s review some recent developments.
CMS has added a new physician specialty code specifying “Micrographic Dermatologic Surgery” (MDS): D7. This new designation will become effective on Oct. 1, 2020, and implemented on Oct. 5, 2020. (See MLN Matters MM11750 (PDF download).
What should you do if you are a Mohs surgeon?
You have a choice of designating yourself in the Medicare Provider Enrollment, Chain and Ownership System (PECOS) as a Mohs surgeon. Also, when initially applying for enrollment in the Medicare system, you may want to designate yourself as a Mohs surgeon with specialty code D7.
Why would it be wise to self-designate as a Mohs surgeon?
Consider the physician specialty designation as a potential harbinger to limiting Mohs surgery reimbursement to physicians designated as Mohs surgeons with code D7. Will this happen? No one can predict. However, be prepared.
More Mohs developments
CMS initiated a Comparative Billing Report (CBR) on Mohs surgery. CBRs generate comparative data reports for CMS, MACs, and physicians. These data are intended to educate physicians so that they can improve any outlier practice patterns impacting their billing.
Select claims data is gathered on individual physicians, and that data is then compared to state and national averages. CBRs do not identify or imply improper claims adjudications or improper payments. They do, however, identify billing outliers. The Mohs surgery CBR was a national initiative that examined data for one year, from August 2018 through July 2019. During this period, 2,928 physicians submitted claims for Mohs surgery.
The CBR analyzed the following metrics based upon the billing of Mohs CPT codes 17311, 17312, 17313, and 17314:
% of Mohs procedures billed with add-on codes for additional stages
Average dollars per procedure for Mohs microsurgery with add-on codes for additional stages
% of beneficiaries receiving Mohs with add-on codes for additional stages
State and national means were calculated for each of the above criteria. Individual Mohs surgeon’s data was compared with their state and national statistics. Significantly high outliers for each of the three categories were identified, and these physicians received a CBR notice. CBR notices to physicians are generated when the physician scores higher than the 90th percentile in any one of the three above metrics as compared to either the state or national mean values.
Physicians who meet or exceed the 90th percentile criterion should have received a notice of a CBR by email or fax, and a copy of the entire CBR by mail. Anyone receiving a CBR should consider its implications: You are an outlier. That may be entirely due to your patient mix.
The CBR does not imply wrongdoing and is not a precursor to a focused audit. Medicare states that it is only for informational purposes so that the Mohs surgeon can review their coding and billing patterns to ensure accuracy. However, also keep in mind that MACs can identify substantial statistical outliers and then focus audit them.
Only physicians who score above the 90th percentile will receive CBR notices. Those who do not receive a notice cannot access their CBR report online.
Example 1
You receive a CBR report designating that you are a significantly high statistical outlier in one or more CBR criteria. You are trembling in anticipation of a focused audit and meanwhile alter your utilization patterns aiming to fall below the outlier status. You expect a follow-up report confirming a change in your billing patterns.
Answer: Incorrect. The project produces a one-time notification of outliers. There is no follow-up report. No response is required from the Mohs surgeon. The CBR does not forward its data to any auditing bodies. Consequently, it is not a definite precursor to an audit. However, consider that Medicare MACs keep track of outlier data and may independently employ it to focus audit severe outliers.
Example 2
One of your colleagues received a CBR report and you did not. You feel left out of the data loop and would like to examine your specific data. You access the CBR website and request your report.
Answer: Nice try. Reports are only available to those meeting significantly high statistical criteria and are not produced by request.
Example 3
You are a Mohs surgeon. You are doing just fine and see no reason to worry about changing anything in PECOS or with Medicare.
Answer: Just do it! No rush now, but once the D7 Mohs physician specialty code becomes effective on Oct. 1, ensure that you are designated in the PECOS system with MDS physician specialty code D7 (taxonomy code 207ND1010X). Avoid assuming that it will be done for you, and that your designation will be correctly entered in the PECOS system without your participation.
