January 16, 2008

Dear ASMS Member:

We have received several requests to provide patient information that clearly outlines the recent Mohs Medicare reimbursement changes. The explanations and billing examples below outline the impact of the reimbursement changes that are now in place. I hope that you find the information helpful, and that it will encourage you and your patients to contact CMS and your legislators concerning this issue.

Beginning on January first of this year Medicare has reduced reimbursement for Mohs surgery. Private insurers are likely to follow Medicare’s lead. Specifically, first stage excision Mohs codes 17311 and 17313 will be subject to a 50% multiple procedure payment reduction. Consequently, when Mohs surgery and reconstruction are done on the same day, the lower valued of the two procedures, either the first stage Mohs excision or the reconstruction, will be reimbursed at 50% of its contracted value. Second, third, and greater stages of Mohs excision (codes 17312, 17314, 17315) will be reimbursed at full contracted rates, without any reduction. Reconstruction done on any day after the day of Mohs surgery will be reimbursed at the full contracted rates and is not subject to any reduction in payment.

The decrease in Mohs reimbursement was made unilaterally, without logical explanation and despite strong opposition from Mohs surgeons and national dermatologic societies. The new reimbursement rule may in some instances require Mohs surgeons to provide services at less than cost. In order to work within the new guidelines and for the surgeon(s) to be paid fully for both the Mohs excision and the reconstruction, patients can be referred to another physician for same-day reconstruction or they can return on a subsequent day for repair by the original Mohs surgeon. Furthermore, given the reduction in reimbursement, patients who have two distinct lesions requiring Mohs surgery are less likely to have them done on the same day. As a group, dermatologists find this change unacceptable. Potential solutions can be costly and inconvenient to dermatologists, patients and patient families.

During this transition period, we ask for your patience and understanding. We hope that your dissatisfaction with this rule will motivate you to write your comments to Medicare and your legislators.

Listed below are the contact information for CMS (Medicare) and the website access for finding and e-mailing your federal legislators.

Medicare Contact Information
Kerry Weems, Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attn: CMS-1385-FC
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

To Obtain Address and Email Information for Legislators
www.house.gov
www.senate.gov

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The following are several billing scenarios and the 2008 Medicare Reimbursement Rates
Note: When the multiple surgical procedure reduction rule (MSRR) is applied, the highest RVU valued code is reimbursed at 100% and the lesser valued code is reimbursed at 50%.

 

Example 1
Two stages of Mohs surgery on nose; adjacent tissue rearrangement repair (less than 10 sq cm)
 

CPT	Medicare Reimbursement as % of Fee Schedule
17311 - Mohs 1st stage	50%
17312 - Mohs 2nd stage	100%
14060 - Flap repair, nose	100%

Example 2
One stage of Mohs on forehead lesion with intermediate repair + two stages of Mohs on scalp lesion, no repair done
 

CPT	Medicare Reimbursement as % of Fee Schedule
17311 - 1st stage, forehead	100%
17311-59 - 1st stage, scalp	50%
17312 - 2nd stage, scalp	100%
12051 - Intermed., repair, forehead	50%

Example 3
One stage of Mohs on forehead lesion + two stages of Mohs surgery on scalp lesion followed with 15 sq cm adjacent tissue rearrangement repair

CPT	Medicare Reimbursement as % of Fee Schedule
17311 - 1st stage, forehead	50%
17311-59 - 1st stage, scalp	50%
17312 - 2nd stage, scalp	100%
14021 - Flap repair, 15 sq cm	100%

The above examples can serve as guides for calculating reimbursement for Mohs surgery and reconstruction done on the same day as well as for multiple Mohs surgeries done on one patient on the same day. Despite the harsh financial realities of Mohs payment reductions, let us not deviate from our primary focus: proper and ethical patient care.

Sincerely,

Alexander Miller, M.D.
President

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