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A Happy Resolution to the Q Codes Issue
No, the Q Codes are not part of some spy thriller. They come from the equally arcane world of Medicare documentation. When AIRA was first informed that Medicare intended to change the five CPT codes for adult Hepatitis B vaccine, reducing them to three Q codes, it did not seem to be of concern to registries. After all, most registries have not included vaccinations of the Medicare age group, much less the Medicare end stage renal disease patients to whom this change was targeted. Fortunately, Kay Jewell, a physician in Oregon, who made the initial contact with Jeff Weihl of CIRSET and AIRA, was persistent in following up. Kay was a consultant to SMT, a consulting organization in New Jersey, whose VP, Nevin Whitelaw, attended the Registry Conference in Philadelphia where he met with and informed AIRA members of the real potential consequences of this change.
We then understood that even though these changes would seem to affect a small class of adult patients in dialysis, the use of Medicare codes by their intermediaries and commercial carriers and their adoption by some state Medicaid programs would widen the impact well beyond the original intent. Additionally, such changes would seem to be contrary to HIPAA objectives of simplification, as it would burden provider offices with the kind of coding duplication that HIPAA seeks to eliminate. With the proposed Q Codes already published in the Federal Register for a January 03 effective date, carriers were revising their code sets. The time for action was immediate.
SMT had already scheduled meetings with Tom Grissom, the Medicare Director, and Dennis Smith, the Director of Medicaid and State Operations, to make the case against Q codes for dialysis patients, and they invited AIRA representatives to attend to make the case for registries. Sue Salkowitz prepared testimony for these meetings and had the opportunity to present in person, while Jeff Weihl and Terry Hughes “attended” via phone. Sue explained that, because registries and other public health reporting rely on information from health care providers, it is important to retain levels of standardization and code granularity in administrative data from claims and encounters. This can also supplement other forms of surveillance data needed in the current bioterrorism preparedness climate. She asked Tom Grissom to consider these public health needs and withdraw the Q code changes. AIRA members and other registry stakeholders were urged to send letters to CMS and NCVHS to press for the Q code change withdrawal. Sue sent one more follow up letter to Tom Grissom.
Tom Grissom replied:
“Susan, we intend to stick with CPT codes per your request. We are trying to figure out how to do it as easily and as promptly as possible. Unfortunately, CMS is left with this sticky issue of separate vaccines, different doses, different costs, etc. But we are trying to administer the program in a way that balances out all stakeholder interests and you have made us aware of yours.”
It appears that AIRA’s advocacy for registries was very influential. We owe thanks to Mr. Jan Wolters and Swami Nathan of Merck & Co. and SMT for orchestrating these meetings and providing us the opportunity to make our case to the key decision-maker.
Source: Susan Salkowitz