April 19, 2018

NCD Updated for Cardiac MRI and Implanted Devices

Medicare beneficiaries with implanted pacemakers or cardioverter defibrillators are now eligible to receive magnetic resonance imaging (MRI) under conditions defined in an updated National Coverage Determination (NCD) from the Centers for Medicare & Medicaid Services (CMS).

Earlier this year, the American College of Cardiology (ACC) joined with the American College of Radiology (ACR), the Heart Rhythm Society and the Society for Cardiovascular Magnetic Resonance to write a letter supporting changes proposed by CMS to expand MRI coverage for patients with implanted cardiac devices. Specific modifications recommended in our comment letter covered the following: pacemaker dependent-patients, a minimum waiting period after device implantation, abandoned leads and supervision standards. All of our recommendations were incorporated into the final decision memo.

The policy is effective as of April 10, 2018, though it usually takes several months for CMS and Medicare Administrative Contractors to update claims processing protocols.

The following Frequently Asked Questions (FAQs) should help clinicians begin providing MRI services to these patients. If other issues arise, please email your questions to advocacy@acc.org.

Does the policy require the qualified clinician [physician, nurse practitioner (NP), or physician’s assistant (PA)] to be in the MRI suite/lab for the duration of the MRI?

No. “Direct supervision” is defined identically in federal regulations for both the hospital and physician office setting. The qualified clinician “must be immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the [clinician] must be present in the room where the procedure is performed.”

But the policy states that patients must be observed by visual and voice contact and that an advanced cardiac life support (ACLS) provider must be present for the duration of the scan. Doesn’t that mean a qualified clinician needs to be there?

No. It would be inconsistent to allow direct supervision – where the clinician is nearby but not necessarily in the room – but then also require personal presence. Criteria for continuous visual and voice observation and presence of an ACLS provider are described in separate bullets in the policy. The technologist would maintain visual and voice contact. An individual with ACLS certification – who may or may not be the same technologist – must be present. This individual need not be the qualified clinician.

Since the policy requires the device be reinterrogated immediately after the MRI to confirm proper function, what CPT® codes should be used?

Codes 93286 and 93287 should be billed to report peri-procedural programming of pacemakers and implanted cardioverter defibrillators (ICDs), respectively. These peri-procedural services are billed before and after the MRI procedure. If one clinician performs both pre- and post-MRI evaluations, the code is reported twice. If one clinician performs the pre-MRI service and a different individual performs the post-MRI evaluation, each would bill once.