CLARIVEIN UPDATES

Vascular Insights, LLC has obtained CPT codes through the AMA for their ClariVein mechanochemical system.  The codes are 36473 for the first vein treated and code 36474 for the subsequent vein treated.  Only the RVU’s are readily available at this moment.  Based on the RVU calculations, reimbursement should come in just under the RF (36475/36476) reimbursement amounts for your area.  These codes will be effective starting January 1, 2017.

Before January 1, 2017, you should continue billing using either the 37799 for most areas or 36299 for Noridian.  We do understand, particularly with Noridian, that there are some difficulties in receiving appropriate reimbursement.  While the code 36473 will not be in effect until January 1st, we do recommend referencing the RVU’s for the code in any appeal letters.  Noridian and the other payers are supposed to pay based on the assumed RVU’s using your operative report.  Now that there is a default standard for the RVU’s it may be easier to obtain proper reimbursement.  The link for RVU information is:  https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/PFS-Federal-Regulation-Notices-Items/CMS-1654-F.html

That’s the good news…  Now on to the bad news…

We have several instances from both the east coast and the west coast of Medicare recouping monies paid to a practice using the 37241 for billing the ClariVein procedure.  The recoupments have been for ALL claims paid using that code between January 1, 2014 and current.  Unfortunately, for some practices this may be in the range of several hundreds of thousands of dollars.

Our recommendation is to begin accruing monies to offset this potential liability if you have used this code for this device.  We also recommend you review Medicare’s OIG guidelines regarding refunding and recoupment of monies for inappropriate code use.  The link for the OIG regarding self-disclosure is:  https://oig.hhs.gov/compliance/self-disclosure-info/files/Provider-Self-Disclosure-Protocol.pdf