Legislative, regulatory updates impact dermatology

Dr. Coldiron

The final rule in the Federal Register for dermatology diagnostic codes and reimbursement, scheduled to start January 1, 2020, is different from what was originally proposed.

“The final rule will no longer collapse the two codes into two sets,” said Brett Coldiron, M.D., a clinical associate professor of dermatology at the University of Cincinnati in Ohio. “Instead, there will be new evaluation and management codes that will benefit dermatology because they are based on medical decision-making.”

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In addition, the expected loss of the global periods (follow-up patient visits built into the original code) and the modifier 25 (performing two significantly different procedures on the same day, with separate allowable billing for each) have at least been temporarily shelved by the Centers for Medicare and Medicaid Services (CMS).

“But CMS is hinting that it may indeed remove the global periods from our codes next year,” said Dr. Coldiron, who provided a legislative and regulatory update at the Fall Clinical Dermatology Conference. “That would be catastrophic for dermatology,” representing on average a $100,000 reduction in annual income from Medicare alone for each practicing dermatologist.

“If the legislation passes, we will have to try to turn around and bill the patients for those follow-up visits, which will not be very popular,” said Dr. Coldiron. “Can you imagine asking granny to pay a co-pay to have her sutures removed from a procedure ten days ago?”

For actinic keratosis (AK) destruction, reimbursement would drop from $67.67 to $24 without global periods. 
Due to this potential loss in income, Dr. Coldiron urges dermatologists to financially donate to SkinPAC, the political action committee of the American Academy of Dermatology (AAD).

“More money will allow us to have access to legislators, so that we can explain our dilemma to them,” said Dr. Coldiron, the current chair of SkinPAC.

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Physician rosters that the insurance companies publish and make available to their patients also need to be accurate to avoid surprise medical billing. “Right now, these roosters are 76% inaccurate with a list full of deceased doctors and residents who have moved on to other positions,” Dr. Coldiron said. “However, many insurance companies do not seem to care at all about keeping their rosters up to date.

For those practices who would rather sell their practices to private equity than face an uncertain financial future, “private equity is not truly buying your practice, they are fronting you a loan for five years,” Dr. Coldiron said. “As a result, you will no longer have the choice of who to send your dermatopathology to or your Mohs surgery or anything else you refer out. All these services will be funneled into the private equity’s system, so it may be a referral you do not like.”

Dr. Coldiron added that private equity takes 20% off the top.

“The ultimate losers are the patients who lose the advantage of having the best possible specialist treat them,” he said.

Disclosures:

Dr. Coldiron is the current chair of SkinPAC.

References:

Coldiron B. Legislative and Regulatory update and its impact on you. Presented at the Fall Clinical Dermatology Conference; October 17, 2019; Las Vegas, NV.