By Jim Gajewski, M.D., ASBMT Practice Policy Consultant
On Oct. 2, the Centers for Medicare & Medicaid Services (CMS) implemented our new specialty designation for HCT physicians – hematopoietic cellular transplant and cellular therapy (HCTCT) physicians. Over the next 60 days, HCT physicians should contact their hospital billing offices to ask for this specialty change on CMS paper forms CMS 855I or CMS 855O or to do this electronically on the Internet Based Provider Enrollment, Chain and Ownership System (PECOS). This will alert the local Medicare administrative contractor to change specialty designation. Many have asked what the implications of the specialty change will do for HCT physicians. Some of the common questions have been:
- What are the implications under MACRA for separate specialty designation?
Under MACRA, physicians will be compared to physicians in the same specialty for costs per patient and outcomes. Without this change, HCT physicians will be compared to community practice hematology oncology physicians whose patients rarely require long hospitalizations. This way HCT physicians will be compared to physicians managing similar populations of patients. Sadly, this will not be helpful for Nurse Practitioners and Physician Assistants as CMS does not designate those providers by specialty.
- What are the implications if the Affordable Care Act is preserved for separate specialty designation?
ACA requires each insurance listed in the exchange to have physicians representing each specialty to provide care for patients. While most patients have had access to HCT physicians for transplant access, there has been access issues with patient post HCT with transplant related complications. This would require all plans to have a HCT physician in network. However, this will not require a facility to be in network.
- Will this increase the value of the relative value units HCT providers earn for evaluation and management or procedural CPT?
No. Relative value units assigned to each CPT code are specialty neutral. Thus there will be no change in RVU values for evaluation and management services.
- Will this help us doing same patient care visits with the doctor who referred patient for transplant or when we need a benign hematology consult?
Yes. The problem has often been same day with 2 physicians from the same specialty. With HCT physicians now having a different specialty designation, this should be less of a problem. Hematology oncology had several options to have dealt with this issue as CMS already had separate taxonomies for hematology, medical oncology and hematology & oncology. This will give another option and an option reflective of services HCT doctors provide. In HCT case rates, this new designation will allow us to track the services HCT physicians provide. The new hematopoietic cell transplantation and cellular therapy specialty code is C9.
- In the future, what are other anticipated benefits to the separate specialty designation?
Facilities and commercial payers are trying to limit complex therapy to be provided by appropriately trained and credentialed physician providers. Many CAR T cell manufacturers will want to limit their therapy to experienced providers. This will enable identification of such providers of HCT and cellular therapeutics in claims data. When FACT accredits a center, this will enable identification easily of physicians performing hematopoietic cellular transplants and cellular therapeutics.
- Will this mean HCT physicians will need a separate board exam to identify themselves as a member of this new specialty? Will HCT physicians need a new maintenance of certification process or exam to take?
No! CMS specialty designation is a self-description by physicians not linked to any board exam. Board certification and maintenance of certification will remain through traditional specialty boards sponsored by the American Board of Medical Specialties, American Board of Internal Medicine and American Board of Pediatrics. There will be no new HCT board exam or maintenance of certification exam as part of this process.
- Should I list HCTCT as primary or secondary specialty choice? If I list HCTCT what should I list as my secondary specialty choice?
With MACRA mechanisms of tracking cost of care per episode and ACA sponsored insurance plans specialty access, the impact of secondary specialty for classification is unknown. The best suggestion we have at the moment is to list HCTCT as primary specialty for MACRA and ACA. Secondary specialty could be listed as either hematology, hematology-oncology, medical oncology, internal medicine, pediatrics or left blank. Secondary specialty like primary specialty for Medicare is also a self-designation and does not need to be in designation of a physician’s passed and active board examination status. An advantage to listing internal medicine or pediatrics as secondary is some insurance plans want orders to be within scope of practice. HCT physicians are often doing primary care orders for patient for general medical diseases like diabetes and hypertension and secondary designation as internal medicine or pediatric. At the moment option suggestions for secondary designation remain in flux.
If you have questions about this new specialty designation, please contact James Gajewski, MD, at jamesgajewski@asbmt.org.