Medicare Reimbursement And
The Vascular Lab: An Overview

from the Spring 2002 issue

The Intersocietal Accreditation Commission (IAC) receives numerous phone calls and e-mails each week from individuals who are concerned with their compliance to state Medicare reimbursement policies. Over the past several years, several states have adopted payment policy for the reimbursement of noninvasive vascular procedures, requiring either credentialing of individuals performing examinations or accreditation of the laboratory. A complete state-by-state listing of payment policies of which the ICAVL is aware can be found at Terms By State.

BACKGROUND

In 1996, the Health Care Financing Administration (HCFA), now the Centers for Medicare and Medicaid Services (CMS), published a directive as a recommendation for the reimbursement of noninvasive vascular studies. However, the final decision on whether to implement a policy requiring certification of laboratory personnel and/or accreditation of the laboratory was left up to each individual state’s Medicare carrier. For that reason, there has been a wide range of activity with regard to implementation of the template payment policy.

For example, Louisiana was the first state to publish a policy, with a requirement for Medicare Part B studies that became effective on January 1, 1998 requiring the RVT or RVS credentials for laboratory personnel or ICAVL laboratory accreditation. Since that time, the ICAVL is aware of implementation of similar policies by 32 other states, one region (Washington, DC) and one territory (Puerto Rico). These include a recommendation, rather than a requirement, set forth by Noridian Mutual Insurance Company, the carrier for Arizona, Alaska, Colorado, Hawaii, Nevada, North Dakota, Oregon, South Dakota and Wyoming. The most recent payment policy, which will become effective June 6, 2002 for Medicare Part B studies in Illinois and Michigan, was announced by the carrier, Wisconsin Physicians Service, in November 2001. Because of this particularly short implementation time, the ICAVL, as a service to the vascular community, sent a mailing to vascular laboratories in the ICAVL database and to credentialed technologists and sonographers alerting them to this new policy and providing a link to the carrier’s Web site where the payment policy is published.

THE BIG QUESTION: PART A OR PART B

While the majority of the policies described above are in effect for Medicare Part B, the ICAVL is also aware of a limited number of policies for Part A. When determining whether the noninvasive vascular studies performed in your laboratory are impacted by a specific policy, the fact that the study is performed in a hospital does not necessarily mean the entire study is billed to Part A. Part A usually covers the technical component of studies performed in hospitals while Part B covers the professional component—the interpretation. In general, studies performed in private offices and clinics are reimbursed entirely under Part B, however, this information should also be confirmed with laboratory administrators to determine whether the studies performed by your laboratory are impacted by a specific payment policy.

HOW ARE MEDICARE REIMBURSEMENT POLICIES ENFORCED?

Medicare payment policies are enforced through post-payment audits. This means that at any time after a policy’s implementation date, an audit can be conducted by Medicare to ensure compliance. This includes audits brought about by a complaint regarding compliance from employees, past or present, competitors or patients. Laboratory records, including log books, are reviewed to ascertain compliance. Providers found to be noncompliant with payment policies must repay the provider for past claims and are often assessed a penalty for each past claim.

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