Health Policy and Government Relations

Medicare Coverage For Dialysis Access Duplex Studies

CMS sent a Program Memorandum to their Medicare Carriers last week regarding payment for vascular laboratory study CPT 93990, "duplex scan of hemodialysis access (including arterial inflow, body of access and venous outflow)".  The implementation date for this policy is January 1, 2002, although several regional carriers already follow similar payment guidelines.

In essence, CMS will not pay for 93990 or any other noninvasive vascular lab studies obtained to "monitor" the function of a patient's vascular access site.They will pay when 93990 is obtained to evaluate an access with signs and symptoms of malfunction such as elevated dynamic venous pressure (>200 mmHg) during dialysis (pump set on 200 cc/min), access recirculation of 12% or greater, or an otherwise unexplained urea reduction ratio <60%.

The PM also includes as an appropriate indication for 93990 "an access with a palpable pulse on examinaton". We are not sure exactly what they mean by this, and the question has already been posed to CMS by others. They may be implying that an access with an outflow stenosis would have a strongly palpable "water-hammer" pulse, therefore deserving evaluation, OR perhaps this line represents a typo. We will send you a clarification when available.

Finally, CMS will not pay for both a noninvasive access study and an arteriogram (fistulogram/venogram) UNLESS documentation to support medical necessity for both is provided. They say "An example of when both studies may be clinically necessary is when a Doppler flow study demonstrates reduced flow (blood flow rate less than 800cc/min or a decreased flow of 25% or greater from previous study) and the physician requires an arteriogram to further define the extent of the problem. The patient's medical record(s) must provide documentation supporting the need for more than one imaging study."

Other relevant information is included in this PM, number AB-01-129, and we suggest you read it carefully. It can be downloaded from the CMS website at http://www.hcfa.gov/pubforms/transmit/AB01129.pdf OR you may review the entire list of recent CMS Program Memos at http://www.hcfa.gov/pubforms/transmit/memos/comm_date_dsc.htm.

VS News is sent to you by the Government Relations Committee of the American Association for Vascular Surgery. Incidentally, the AAVS GRC was not asked to comment on this PM prior to publication. We are not sure if there is likelihood for revision, but if you have significant concerns about the policy please email suggested revisions along with a strong justification to Brenda at Robert.M.Zwolak@HITCHCOCK.ORG.

If substantial concern exists in the vascular surgery community we will determine the means to appeal. Thank You.

Society for Vascular Surgery - 633 N. St. Clair, 24th Floor; Chicago, IL 60611; Phone: 312-334-2300 or 800-258-7188; Fax: 312-334-2320; Email: vascular@vascularsociety.org
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