The College and the ACAAI Advocacy Council recently wrote to CMS Administrator Mehmet Oz, MD, requesting that Medicare rescind its current definition of the 1 cc dose for allergen immunotherapy and replace it with the CPT definition that is used by most insurance companies. We emphasized that having multiple dose definitions “… creates a confusing inconsistency with what is documented in the patient’s clinical medical records. In addition, all practitioners billing allergy extract have had to maintain a dual definition of the units for CPT code 95165; one for Medicare and one for all other payers. This creates an administrative burden on allergy practices, particularly small practices” and conflicts with the administration’s “emphasis on rescinding regulations and guidance documents that burden American businesses, particularly small and rural business.”
We also requested a meeting with CMS to discuss the issue further. Congressman Robert Onder, MD, FACAAI (R-MO-03) and many other members of Congress are working closely with us to ensure our patients continue to receive appropriate care, and allergists are paid fairly for the services they provide. Discussing the issues surrounding fair payment for allergy extracts was a focus of our recent visits with more than two dozen congressional offices during our Strike Force visits earlier this month.
It’s important to realize that very few people understand immunotherapy and its unique process/protocol. In addition to the above request, we explained the background of immunotherapy and the confusion that can arise when two definitions describe the same procedure. The Medically Unlikely Edits (MUEs) of 30 for CPT Code 95165 further demonstrates CMS’s misunderstanding of the way allergy immunotherapy is prepared and provided.
With the administration’s emphasis on rescinding regulations and guidance documents that affect American businesses, we are hopeful CMS will grant our meeting request, and that we will soon have a single definition of a dose for CPT 95165 and that all payers in the United States will then use. Do not change any of your billing procedures until you receive confirmation from us that our efforts have paid off and our request has been approved and implemented.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
