DOBI Proposal Would Overhaul PIP Regulations And Cut Reimbursements For Certain ProceduresOctober 9, 2017

On October 5, 2017, the New Jersey Department of Banking and Insurance (DOBI) provided advance notice of proposed amendments to the PIP regulations, including fee schedule adjustments, CPT code updates, and a ban on reimbursement for Thermal Intradiscal Procedures.

DOBI seeks to update the regulations to reference the 2017 CPT manual instead of the outdated 2011 manual. Code references for nerve conduction tests would also be updated.

DOBI also intends to add columns to the Physicians’ Fee Schedule to address procedures subject to rules related to multiple procedure reductions, bilateral procedures, assistant surgeons and co-surgeons.

In addition, N.J.A.C. 11:3-29.4(f)(8) would be amended to indicate that devices would not be reimbursable where the price of the device is included in the facility fee schedule amount.

DOBI proposes a ban on reimbursement for Thermal Intradiscal Procedures.

The daily maximum fee for certain Physical Medicine and Rehabilitation codes would be increased from $105 to $110.

Importantly, under the new fee schedule reimbursement for key CPT codes would be reduced. Although DOBI indicates that the majority of codes would receive an upward adjustment, certain codes and fees would be cut, because “the fee would be significantly higher than fees in similar CPT families under 2017 Medicare … or the fee would be an outlier in its CPT code family.”

The fee schedules would also be updated to reflect amendments made by the Center for Medicare and Medicaid Services (CMS), including the addition of procedures now eligible for reimbursement by CMS when performed in ambulatory surgery centers.

Drafts of the proposed fee schedules can be found on DOBI’s website via this link. All providers should carefully review the proposed fee schedule to determine how it would affect their practices.

Comments on the proposals are due by November 6, 2017. Brach Eichler intends to submit formal comments to DOBI concerning all proposed regulatory changes. We welcome your input while drafting our position for submission.

Attorney: Keith Roberts

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