CMS Imposes Prior Authorization for Specified Outpatient Procedures

February 4, 2020

Monica Lelevich
Director, Audit Services

Medicare recently finalized a plan that will require hospitals to obtain prior authorization before performing certain outpatient procedures. Understanding these changes will be critical to avoid unnecessary denials beginning on July 1, 2020.

The new prior authorization rules, which were outlined in the 2020 Medicare Hospital Outpatient Prospective Payment System (OOPS), are primarily for services that are sometimes performed for cosmetic purposes and have been identified by the Centers for Medicare and Medicaid Services (CMS) as being at-risk for incorrect payment due to medical necessity concerns.

The prior authorization final rule was published in the Federal Register on Nov. 12, 2019, in Section XIX under “Prior Authorization Process and Requirements for Certain Hospital Outpatient Department (OPD) Services.”

Masking cosmetic procedures

According to the rule, CMS conducted an analysis of over 1 billion claims relating to outpatient department services (OPD) dating from 2007 to 2017. The agency determined that utilization volume increased significantly during that period, from approximately 90 million to 118 million. In addition, the Medicare allowed amount for OPD more than doubled, from $31 billion in 2007 to $65 billion in 2017.

To reduce improper outpatient claims, CMS specifically targeted Medicare cosmetic surgical procedures that may be combined with, or masquerade as, therapeutic services. CMS’ analysis indicated the following outpatient procedure categories had higher-than-expected volume:

  1. Blepharoplasty
  2. Botulinum toxin injections
  3. Panniculectomy
  4. Rhinoplasty

July 2020 deadline

Prior authorization for the specified list of procedures found under these categories (see below) must be obtained for services performed on or after July 1, 2020. In theory, the authorization process should take no more than 10 days. Either the physician or the hospital may submit the request for prior authorization, but the hospital will remain ultimately responsible for ensuring that authorization is obtained prior to the surgical procedure.

To help prevent unnecessary denials, be sure your staff is fully aware of the specific procedures that now require prior authorization. Be sure to watch for news from your local Medicare Administrative Contractor (MAC) as the July 1 implementation date approaches because the MACs will be responsible for organizing the authorization request process.

Table 65: Proposed List of Outpatient Services That Would Require Prior Authorization [1]

Code(i) Blepharoplasty, Eyelid Surgery, Brow Lift, and Related Services
15820Removal of excessive skin of lower eyelid
15821Removal of excessive skin of lower eyelid and fat around eye
15822Removal of excessive skin of upper eyelid
15823Removal of excessive skin and fat of upper eyelid
67900Repair of brow paralysis
67901Repair of upper eyelid muscle to correct drooping or paralysis
67902Repair of upper eyelid muscle to correct drooping or paralysis
67903Shortening or advancement of upper eyelid muscle to correct drooping or paralysis
67904Repair of tendon of upper eyelid
67906Suspension of upper eyelid muscle to correct dropping or paralysis
67908Removal of tissue, muscle, and membrane to correct eyelid dropping or paralysis
67911Correction of widely opened upper eyelid
Code(ii) Botulinum Toxin Injection
64612Injection of chemical for destruction of nerve muscles on one side of face
64615Injection of chemical for destruction of facial and neck nerve muscles on both sides of face
J0585Injection, onabotulinumtoxina, 1 unit
J0587Injection, rimabotulinumtoxinb, 100 units
Code(iii) Panniculectomy, Excision of Excess Skin and Subcutaneous Tissue (Including Lipectomy), and Related Services
15830Excision, excessive skin and subcutaneous tissue (includes lipectomy); abdomen, infraumbilical panniculectomy
15847Excision, excessive skin and subcutaneous tissue (includes lipectomy), abdomen (e.g. Abdominoplasty) (includes umbilical transposition and fascial plication) (list separately in addition to code for primary procedure)
15877Suction assisted removal of fat from trunk
Code(iv) Rhinoplasty, and Related Services
20912Nasal cartilage graft
21210Repair of nasal or cheek bone with bone graft
21235Obtaining ear cartilage for grafting
30400Reshaping of tip of nose
30410Reshaping of bone, cartilage, or tip of nose
30420Reshaping of bony cartilage dividing nasal passages
30430Revision to reshape nose or tip of nose after previous repair
30435Revision to reshape nasal bones after previous repair
30450Revision to reshape nasal bones and tip of nose after previous repair
30460Repair of congenital nasal defect to lengthen tip of nose
30462Repair of congenital nasal defect with lengthening of tip of nose
30465Widening of nasal passage
30520Reshaping of nasal cartilage
Code(v) Vein Ablation and Related Services
36473Mechanochemical destruction of insufficient vein of arm or leg, accessed through the skin using imaging guidance
36474Mechanochemical destruction of insufficient vein or arm or leg, accessed through the skin using imaging guidance
36475Destruction of insufficient vein of arm or leg, accessed through the skin
36476Radiofrequency desctruction of insufficient vein of arm or leg, accessed through the skin using imaging guidence
36478Laser desctruction of incompetent vein of arm or leg, accessed through the skin
36479Laser desctrustion of insufficient vein of arm or leg, accessed through the skin using imaging guidance
36482Chemical destruction of incompetent vein of arm or leg, accessed through the skin using imaging guidance
36483Chemical destruction of incompetent vein of arm or leg, accessed through the skin using imaging guidance

Your AR specialists

ParaRev specializes in accounts receivable recovery and resolution and serves as a virtual extension of your hospital central billing office to help you quickly resolve and collect more of your insurance accounts receivable.

We utilize proprietary intelligent automation and staff specialization to efficiently process all claims regardless of size or age. In addition to our resolution capabilities, ParaRev also can provide denial management assistance by conducting root cause analysis and recommend process improvements to help decrease aged and denied claims going forward.

Contact ParaRev today to learn more about how we can help you with your hospital’s accounts receivable management.

  1. Federal Register / Vol. 84, No. 218 / Tuesday, November 12, 2019 / Rules and Regulations. Pages 61450-61451.

Gaining control over denials to reduce chronic revenue loss and costly remediation requires accurate information about where, when, and why denials are occurring. ParaRev has identified the top three departments where denials are the most prevalent. Download our whitepaper to learn how to decrease denials and improve margins

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