One of the questions I receive from different physicians throughout the year is: “Will phlebology still be in existence and paid for in the years to come?” My initial answer is “I sure hope so” since we are as invested in phlebology as that physician. My real answer is that I expect the payers to continue to nibble around the edges through restrictions and policies but it will still be here for some years to come.
One new policy is quite interesting. First Coast Service Options, one of the Medicare Administrators (MAC) who oversees Medicare administration for Florida, Puerto Rico, and US Virgin Islands (when can we have our annual congress in the US Virgin Islands?), has put together a very strongly worded Local Coverage Determination (LCD) # L33762 for varicose vein treatment. Even if you are not in Florida, you may want to consider incorporating some of the elements they want into your History and Physical.
The first small consideration is to add an Etiologic, Anatomic and Pathophysiologic classification to your CEAP score. In the age of drop down menus for your EHR, these are pretty simple to add while providing additional information regarding the patient’s disease to the several payers. Even if this is not in that payer’s guidelines you now have further information to use in making your case regarding the need for treatment.
The second item to add to your H&P is the Venous Clinical Severity Score. Again, First Coast Service Options is requiring this documentation. In your area, it may not be required but it again provides a lot of additional information to the payer in an easy to develop drop down menu format in an EHR. Each leg receives a score of 1 to 5 for Pain, Varicose Veins, Venous Edema, Skin Pigmentation, Inflammation, Active Ulcers, Active Ulcer Duration, Active Ulcer Size, and Compression Therapy Compliance. The policy goes on to note higher CEAP and VCSS scores may allow for a waiver of the 90 day conservative therapy requirement.
If the patient has a lower CEAP/VCSS score, conservative therapy is required. Both this policy and many others payer policies are very clearly noting that the rendering provider must take an active role in the conservative therapy process. In short, you can no longer take the patient’s word for stocking wear. Please also keep in mind that conservative therapy is more than just use of stockings. Each patient should be evaluated, diagnosed, and then placed in a conservative therapy management program.
This new policy also had very specific language on when and what treatment is appropriate due to vein size, CEAP and VCSS scores. You may want to consider incorporating these standards as a broad standard of care for your practice.
There are a number of other interesting elements including documentation requirements throughout this new LCD. Of note is specific training for both the physician and for the vascular technologist. For the physician, there are a number of Board certifications they will accept or additional training. The easiest way to show ‘additional training’ is to obtain your ABVLM board certification as the language states: …and expertise endorsed… by the applicable specialty/subspecialty society in the United States.
The policy in its entirety can be found at:
http://medicare.fcso.com/Fee_lookup/LCDDisplay.asp?id=L33762
No comments yet.