American Society of Interventional Pain Physicians®
"The Voice of Interventional Pain Management"
81 Lakeview Drive, Paducah, KY 42001
Phone: (270) 554-9412 - Fax: (270) 554-5394
www.asipp.org
November 2, 2016
Novitas Solutions
Medical Policy Department
Union Trust Building, Suite 600
501 Grant Street
Pittsburgh, PA 15219
Re: PROPOSED/DRAFT Local Coverage Determination (LCD): Vertebroplasty, Vertebral Augmentation (Kyphoplasty) Percutaneous (DL35130)
Dear Carrier Medicare Directors:
On behalf of the American Society of Interventional Pain Physicians, State Societies of Interventional Pain Physicians of Arkansas, Colorado, Delaware, Louisiana, Maryland, Mississippi, New Jersey, New Mexico, Oklahoma, Pennsylvania, and Texas. We would like to thank you for providing us the opportunity to comment on vertebral augmentation draft policy. We have reviewed the draft policy and wanted to bring to your attention errors in the place of coverage and also the provider specialties. This draft policy omitted interventional pain management as a specialty (-09). We request that interventional pain management be added to the policy and all offices covered eligible for interventional techniques.
Interventional pain management is defined as the discipline of medicine devoted to the diagnosis and treatment of pain related disorders principally with the application of interventional techniques in managing sub acute, chronic, persistent, and intractable pain, independently or in conjunction with other modalities of treatment.[1]
Interventional pain management techniques are minimally invasive procedures, including percutaneous precision needle placement, with placement of drugs in targeted areas or ablation of targeted nerves; and some surgical techniques such as laser or endoscopic diskectomy, intrathecal infusion pumps and spinal cord stimulators, for the diagnosis and management of chronic, persistent or intractable pain.[2]
ASIPP is a not-for-profit professional organization founded in 1998 now comprising over 4,500 interventional pain physicians and other practitioners who are dedicated to ensuring safe, appropriate and equal access to essential pain management services for patients across the country suffering with chronic and acute pain. There are approximately 8,500 appropriately trained and qualified physicians practicing interventional pain management in the United States. ASIPP is comprised of 50 affiliated state societies, and the Puerto Rico Society of Interventional Pain Physicians.
We appreciate the comprehensive policy put forth; however, we were disturbed to note the following 2 items:
Place of Service:
Place of service states that all the services require special equipment and potentially moderate anesthesia, they will be billable as inpatient, outpatient, facility, and ASC only. Offices with appropriate equipment will be allowed if billed through Part B providers considered appropriate for billing, i.e. radiology office.
This is inappropriate as interventional pain physicians have provided these procedures ever since their inception. Further, the procedures have been covered by Medicare for interventional pain physicians in all settings including office settings. Interventional pain physicians provide various types of procedures in office settings including spinal cord stimulation trials. The utilization data shows[3],[4] that interventional pain management physicians have performed significant proportion of procedures amounting to 6.8% of the total procedures in 2014. In fact, interventional radiology which is the only specialty quoted here has the policies written by interventional radiologists without consultation with interventional pain physicians, have done very few cases. Because of it and the confusion between interventional radiology and general radiology they are listed under radiology. Many of the anesthesiologists also belong to interventional pain management or pain management specialties in addition to physical medicine and rehabilitation physicians. Medicare fee schedules over the years including 2017 proposed schedule actually reimburses at higher amounts for these procedures to be performed in an office setting, including interventional pain physician offices. There is no guidance for specific radiology office, in fact, radiology offices are very few and majority of the procedures are performed in a hospital setting. Ambulatory surgery centers perform these procedures infrequently since they are not reimbursed adequately.
Consequently, we request that this sentence be changed to cover interventional pain management, pain management, anesthesiology, and physical medicine and rehabilitation.
Provider Qualifications
Provider qualifications is the next issue. While it describes formal training within residency or any specialty it includes only diagnostic radiology, interventional radiology, neurosurgery, and orthopedic surgery. Thus, it omits interventional pain management. As shown above, interventional pain management is a subspecialty drawing members from multiple specialties performing interventional techniques. In fact, this should actually add anesthesiology, physical medicine and rehabilitation, interventional pain management, as well as pain management as approved specialties.
Thus, we hope that you will address these issues and add offices of interventional pain physicians and other related specialties to be added as places to be perform the procedures and interventional pain management as a qualified specialty. If you have any questions, please feel free to contact us.
Sincerely,
ARKANSAS
John Swicegood, MD
Arkansas CAC Representative
Steve Irwin, MD
President, Arkansas Society of Interventional Pain Physicians
COLORADO
Bradley Vilims, MD
Colorado CAC Representative
Kenneth C. Lewis, MD
President and CEO, Colorado Society of Interventional Pain Physicians
DELAWARE
Frank Falco, MD
Delaware CAC Representative
Manonmani Antony, MD
Delaware Alternate CAC Representative
Selina Xing, MD
President and CEO, Delaware Society of Interventional Pain Physicians
LOUISIANA
Patrick Waring, MD
Louisiana CAC Representative
J. Michael Burdine, MD
Louisiana Alternate CAC Representative
Paul Hubbell, MD
President and Executive Director, Society of Interventional Pain Physicians of Louisiana
MARYLAND
Ali El-Mohandes, MD
Maryland CAC Representative
Ira Kornbluth, MD, MA, FAAPMR
CEO, Maryland Society of Interventional Pain Physicians
Raj Jari, MD
President, Maryland Society of Interventional Pain Physicians
MISSISSIPPI
Jeff Summers, MD
Mississippi CAC Representative
Timothy Beacham, MD
CEO and President, Mississippi Society of Interventional Pain Physicians
NEW JERSEY
Peter Staats, MD
New Jersey CAC Representative
Andy Kaufman, MD
New Jersey Alternate CAC Representative
Scott Woska, MD
Executive Director, New Jersey Society of Interventional Pain Physicians
Eric Freeman, DO
President, New Jersey Society of Interventional Pain Physicians
NEW MEXICO
Pamela O. Black, MD
President and Executive Director, New Mexico Society of Interventional Pain Physicians
OKLAHOMA
Jack E. Marshall, MD
Oklahoma CAC Representative
Rico Guerra, MD
President and CEO, Oklahoma Society of Interventional Pain Physicians
PENNSYLVANIA
Mark Bell, MD
Pennsylvania CAC Representative
Kalyan Krishnan, MD
Pennsylvania Alternate CAC Representative
Vahid Grami, MD, MPH
President and CEO, Pennsylvania Society of Interventional Pain Physicians
TEXAS
C.M. Schade, MD
Texas CAC Representative
Graves Owen, MD
Texas Alternate CAC Representative
Larry C. Driver, MD
President, Texas Pain Society
AMERICAN SOCIETY OF INTERVENTIONAL PAIN PHYSICIANS
Laxmaiah Manchikanti, MD
Chairman of the Board and CEO, ASIPP
Paducah, KY
Aaron K. Calodney, MD
President, ASIPP
Tyler TX
Peter Staats, MD
Immediate Past President, ASIPP
Shrewsbury, NJ
Ramsin M. Benyamin, MD
Past President, ASIPP
Bloomington IL
Francis Riegler, MD
President-Elect, ASIPP
Palmdale, CA
[1] The National Uniform Claims Committee. Specialty Designation for Interventional Pain Management- 09. http://www.cms.hhs.gov/transmittals/Downloads/r1779b3.pdf
[2] Medicare Payment Advisory Commission. 2001. Report to the Congress: Paying for interventional pain services in ambulatory settings. Washington, DC: MedPAC. December. 2001. http://www.medpac.gov/publications/congressional_reports/dec2001PainManagement.pdf
[3] Hirsch JA, Chandra RV, Pampati V, Barr JD, Brook AL, Manchikanti L. Analysis of vertebral augmentation practice patterns: A 2016 update. J Neurosurg Sci 2016 Oct 31. [Epub ahead of print]
[4] Manchikanti L, et al. Utilization of interventional techniques in managing chronic pain in Medicare population from 2000 to 2014: An analysis of patterns of utilization. Pain Physician 2016; 19:E531-E546.