The ACR has frequently said that adding a duplex scan can be part of test design, such as the Clinical Examples in Radiology issue that you quote.
I disagree. As Mike said, it is a different/additional test. If you look at government audits of imaging practices that have resulted in large fines, you'll notice that most of them include the billing of a 939xx code without an order.
In the hospital, that order can come from the radiologist, but he must document his intent to order the additional exam and the medical necessity for the individual patient, not just done as protocol without medical necessity being established.
When audited by CERT or RAC, they are going to want to see the order and if it doesn't include duplex, or the report doesn't document the radiologist's reasoning for doing the duplex, it's not going to be allowed. If you don't already, I'd suggest reading a few issues of the Medicare Quarterly Provider Compliance Newsletter. They keyword index can be found here and you can look at some of the articles relating to imaging and see what they look for.
| Index of Medicare Quarterly Provider Compliance Newsletters (April 2020) This index contains key words and phrases cited in current and previous issues of the "Medicare Quarterly Provider Compliance Newsletter." It includes a direct link to the newsletter and the month and year it was released by the Medicare Learning Network®. |
Donna Richmond, BA, RCC, CIRCC, CPC
Senior Healthcare Consultant
T 651-424-4225
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Original Message:
Sent: 6/10/2020 12:39:00 PM
From: Rick Sylvanus
Subject: RE: Compliance issue with adding doppler?
Mike - At some point I brought up that concern as well, because it seems like test design is there mostly to allow flexibility on the number and types of views. However, we have this information that states otherwise:
Quoted from the above page:
Diagnostic Test Orders and Duplex Studies
A common question is whether a test order is necessary to perform a duplex study when an ultrasound has been ordered by the referring physician.
Doppler studies should not be routinely added to ultrasounds. Performing a Doppler study with an ordered ultrasound is considered to be a test design exception, according to the rules for ordering diagnostic tests. The Doppler study must be medically necessary to accurately diagnose the patient, and the radiologist should document a detailed explanation of why the Doppler was medically necessary in the procedure report. (Clinical Examples in Radiology, Vol. 9, Issue 1: Winter 2013).
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Rick Sylvanus
Operations Manager
Southern Delaware Imaging Associates
17503 Nassau Commons Blvd
Lewes, DE 19958
E-Mail: Rick@sdiassociates.com
Office: 302-645-7919 x201
Fax: 302-645-7841
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Original Message:
Sent: 6/10/2020 12:12:00 PM
From: Michael Bohl
Subject: RE: Compliance issue with adding doppler?
Rick,
I don't believe Doppler qualifies as "test dedign - it is a completely different exam and CPT code. IMHO you need an order. It sounds like your protocol is to perform Doppler. It would be nice if we could protocol our way around the ordering requirements, life would be much simpler, but we can't. CMS allows for the use of protocols, but still requires the ordering physician to provide an order within a reasonable period of time.
Mike Bohl
Sent from my phone; please excuse typos.
Original Message:
Sent: 6/10/2020 10:58:00 AM
From: Rick Sylvanus
Subject: Compliance issue with adding doppler?
Forum,
We posed a question a couple days ago on the coding forum but have not received a response yet. Since this is actually more of a compliance question I thought I'd post here to see what you think. This is a slightly modified version of the question we posted on the other forum:
We have the following scenario:
1. We perform dopplers on all US non-OB pelvis and US scrotum.
2. The dopplers are not ordered - they are done as part of our protocol.
3. We have not been charging for the dopplers.
We would like to start charging for the dopplers under specific circumstances. (Specifically, when the patient presents with pain/possible torsion.) It is our understanding that the Test Design Exception allows this as long as we document the medical necessity of adding doppler, and of course document that the doppler was performed, and what the findings are. (We know there are specific elements that need to be included to document limited vs complete doppler as well.) However, it has been suggested that because we are always doing doppler (as part of our protocol), but only charging for it under these specific circumstances, we might have a compliance issue if we proceed with this.
Does anyone have any thoughts on this? Is anyone out there performing dopplers but only charging a portion of them?
Thanks in advance.
Rick
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