Common Ground and Collaboration:

OEIS meetsThe American Vein and Lymphatic Societyformerly the American College of Phlebology

Stephen F. Daugherty, MD, FACS, FAVLS, RVT, RPhS

Chairman, Healthcare Policy and Advocacy Committee

Treasurer

VeinCare Centers of Tennessee Clarksville, TN

No Conflicts

American Vein and Lymphatic Society

Physician Society with Allied Health Members

Membership nearly 2000

44% Vascular Surgery, General Surgery, Int. Radiology

53% Solo Practice

Until 2 years ago, primarily an educational society.

FOCUS

ADVOCACY

RESEARCH

EDUCATION

Healthcare Policy Committee

Standing Committee established July, 2017

Stephen Daugherty, Chairman

Marlin Schul, AVLS President

Steve Elias

Chris Pittman, Chairman of Healthcare Advocacy Committee

Healthcare Advocacy Committee

Chris Pittman, Chairman and AMA Delegate

Vineet Mishra, Vice-Chair and Alternate AMA Delegate

Steve Elias

Stephen Daugherty

John Blebea, AMA RUC Advisor

Marlin Schul, Alternate AMA RUC Advisor

Satish Vayavegula, AMA CPT Editorial Panel Advisor

Michael Graves, Alternate AMA CPT Editorial Panel Advisor

Mel Rosenblatt, IAC- Vein Center Representative

Ken Nguyen, IAC- Vein Center Representative

Julio Vasquez

Margaret Mann

Lornell Hansen

Robert Worthington-Kirsch

Peter Pappas

Zoe Deal

James Albert

Francis Lee

James St. George

Robert White

Director of Healthcare Policy and Advocacy

Started May, 2018

Full-time

Lives in DC area

Medicare Carrier Advisory Committee (CAC)

First Coast Services Organization (Florida)Chris Pittman

Palmetto (7 southeastern states)Stephen Daugherty

AMA

House of Delegates

CPT (CPT Editorial Panel)

– Efforts under way to develop a CPT code for Ultrasound Guided Foam “sclerotherapy”

(Endovenous Chemical Ablation with US Guidance)

RUC (Resource-Based Relative Value Update Committee)

– Valuations on physician work, staff time,

practice expenses

IAC- Vein Center Division

Issues- Limits on mid-level practitioners

Costs per site

Presently for superficial vein treatment only

Insurance requirements for IAC-VC accreditation

Massachusetts Blue Cross

Independence Blue Cross

Centers for Medicare and Medicaid Services

• Merit-based incentives payments (MIPS)

• Alternative Payment Models (APMs)

• Physician-Focused Payment Model Technical Advisory Committee (PTAC)

• Revision of E & M codes

• July draft physician fee schedule regulations and values

• Four-year phase in an office-based supply costs determined by a private contractor with obvious gross errors

• Recovery Audit Contractors (RACs) targeting thermal ablation of saphenous vein codes, announced 2/2019

Society of Diagnostic Medical Sonographers

• Proposed High Level Disinfection (HLD) for transducers even when sterile sleeve is used

• Contrary to American Institute for Ultrasound in Medicine (AIUM) standards.

• Would require multiple and/or new transducers for soaking in disinfectants

• ACP and AVF responded

Position Statements

Saphenous Vein Treatments

Chemical Adhesive

Mechanochemical Ablation (MOCA)

“Non-Compounded Foam” Ablation

Payor InteractionFCSO (Florida Medicare)

November, 2016 “Non-coronary and non-cerebrovascularangioplasty” draft LCD

July, 2017- Another draft LCDWe commented, provided a draft medicalpolicy, and our “Guidelines forManagement of Femoroiliocaval Obstruction”

New Carrier Medical Director (CMD)

Novitas

(Medicare Contractor, 11 states, DC, Indian Health Service)

Superficial Veins

March, 2017 – Commented on draft LCD – 8 signatory societies

May, 2018 – Commented on new draft LCD

Feb, 2019 – LCD published denying coverage for Non-thermalvein ablation techniques

On-going meetings with Novitas

Venous Stenting

September, 2018 – draft LCD excluded physician office as site of service for coverage

October, 2018 – Open Carrier Advisory Committee meeting

OEIS led the comment process

Tahara Mc Guckin

Fastaband Hollander

Shiloh Lakhanpal

Miller Patel

Joshi

Written comments from ACP, AVF, OEIS, CVR and others.

• Palmetto (Medicare contractor for 7 states) Superficial vein treatmentVenous ultrasound

• National Government Services (NGS, Medicare contractor for 10 states)

Accepted Non-Thermal technologies

• Independence Blue CrossRequirement for IAC-vein center accreditation

• BCBS, South CarolinaProposed class V, VI coverage only

Under Development

Position Statements• Physician-made foam including gas composition

• Venous Angioplasty/Stenting

Physician Advocates in Each State• Medicare Carrier Advisory Committees

• Regional Insurance Issues

Dashboard on website for Major Carrier Policies

Guidelines for treatment of PELVIC VENOUS DISORDERS

Patient-Reported Outcome Registry

PRO 2.0 – Coming Soon

Currently – 184 Physicians

118,790 Patients

473,254 Patient Encounters

Visit-Based, not Procedure-Based

Focused on Superficial Vein Disorders

Needs a Deep Vein Disorders Module

POTENTIAL FOR COLLABORATION

Advocacy

- Payor Interactions

- Comments on draft guidelines, medical policies

AMA Issues – House of Delegates

– CPT

– RUC

Medicare – Comments on policies

Accreditation Issues – IAC

AAAHC

SVS?

OEIS/AVLS?

Research

PRO 2.0OEIS RegistryClinical Registry Network?Publish Analyses of Data

Education

Regional Symposia•Pelvic Venous Ultrasound•Practice Management• Sclerotherapy•Pelvic Venous Disorders

Annual Meetings