Coding Analysis Related to Commercialization of the XPANSION Skin Grafting Instruments Provided by The Institute for Quality Resource Management

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The codes provided would be recognized as active payable codes by The Centers for Medicare and Medicaid Services (CMS) and private insurance as well. The payment amounts will vary for private insurance companies. Included in this document are CPT: Current Procedural Coding Terminology Codes used by physicians to report the Medicare and other payers the work performed on a patient. APC: Ambulatory Classification codes which reflect a bundled payment for services performed in a hospital outpatient setting. ASC: Ambulatory Surgical Center codes which reflect the assignment of CPT codes to certain ASC groups which are then priced. DRG: Diagnosis related groups which reflect the assignment of clinically similar patients receiving in this scenario a surgical procedure related to skin grafting. The relative weights are developed by CMS using charge data provided to CMS in prior years. The payments are estimates and do not reflect a hospital s specific payment rate, additions for graduate medical education or disproportionate share adjustments. ICD-9-CM: Codes that reflect the International Classification of Disease Coding and Maintenance committee Version 29 nomenclature for procedures related to autologous skin grafts. Table 1 represents example of CPT codes that are billable when using the XPANSION System. The more likely CPT codes are bolded representing procedures for the lower extremities or feet. CPT codes that have a plus (+) in front of the number are to be used in addition to the previous CPT code. These CPT codes indicate an addition to the main category or previous CPT code. The CPT codes provided represent the 2012 Calendar year codes to be used for autologous skin grafting. Not all codes would be relevant, but are provided for informational purposes only. The payment amounts reflect the most recent update payment rates are based on current law, including the Temporary Payroll Tax Cut Continuation Act of 2011, which provides for a zero percent update for the period of January 1, 2012 to February 29, 2012. The Centers for Medicare & Medicaid Services will work quickly to update MPFS payment rates in the event Congress passes legislation to prevent the negative update from going into effect on March 1, 2012. As changes are made we will provide an update to these payment amounts. The payment amounts do not include the geographic adjustments that vary by the specific wage area index. payment for a non-facility patient care setting would be similar to a physician s office, or a free standing surgery center that may be physician owned and not considered an ambulatory surgical center (ASC). payment in a facility represents the payment a physician would receive when billing the CPT code if the procedure was performed in an inpatient setting, hospital outpatient setting or an ASC. We have included an unlisted CPT code 17999 that should be included to report the work associated with the use of the XPANSION System to do the work of creating the skin for appropriate transplant Phase I Coding Assessment for XPansion Page 1

onto the defect sight. Currently there is not reimbursement associated with the code, however it is carrier priced and efforts with local payers may result in early payment while waiting for the specific new codes. Table 1 CPT Codes for the medical procedure associated with harvesting the tissue, preparation the wound site and then placing the autologous graft. Many of these codes have a 90 day global period. Effective January 2012 placement of skin substitute grafts reimbursement has been lowered to reflect the removal of a 90 day global period. CPT 15002 +15003 15004 +15005 15100 +15101 Description Non Facility Facility tissues), or incisional release of scar contracture, trunk, arms, legs; first 100 sq cm or 1% of body area of infants and children $350.25 $230.77 tissues), or incisional release of scar contracture, trunk, arms, legs; each additional 100 sq cm, or part thereof, or each additional 1% of body area of infants and children (List separately in addition to code for primary procedure) $76.58 $46.29 tissues), or incisional release of scar contracture, face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet and/or multiple digits; first 100 sq cm or 1% of body area of infants and children $400.62 $272.98 tissues), or incisional release of scar contracture, face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet and/or multiple digits; each additional 100 sq cm, or part thereof, or each additional 1% of body area of infants and children (List separately in addition to code for primary procedure) $126.62 $92.92 Split-thickness autograft, trunk, arms, legs; first 100 sq cm or less, or 1% of body area of infants and children (except 15050) $875.45 $733.85 Split-thickness autograft, trunk, arms, legs; each additional 100 sq cm, or each additional 1% of body area of infants and children, or part thereof (List separately in addition to code for primary procedure) $188.23 $112.32 Phase I Coding Assessment for XPansion Page 2

CPT 15120 +15121 Description Non Facility Facility Split-thickness autograft, face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits; first 100 sq cm or less, or 1% of body area of infants and children (except 15050) $866.94 $714.45 Split-thickness autograft, face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits; each additional 100 sq cm, or each additional 1% of body area of infants and children, or part thereof (List separately in addition to code for primary procedure) $211.37 $134.79 17999 Unlisted procedure, skin, mucous membrane, and subcutaneous tissue $0.00 $0.00 Table 2 Provides reimbursement information when the procedure using the XPANSION System is provided to a patient in a hospital outpatient setting. The Ambulatory Center (APC) payment is derived from the specific CPT code that would represent the procedure. The physician would complete a HCPFA 1500 form using the same codes at the hospital outpatient bill referred to as the Universal Billing Form (UB) 2004. The status indicator of T indicates that the payment would be 50% of the allowed amount. The CMS reimburses 80% of the payment rate and the patient is responsible for the 20% copayment. The copayment is often covered by Medicare beneficiary supplemental insurance. The comment indicator CH indicates this is an active HCPCS code in current year and next calendar year, status indicator and/or APC assignment has changed; or active HCPCS code that is discontinued at the end of the current calendar year. Use of Revenue Codes to capture the actual cost of the procedure. The cost of surgical devices included in the procedure, unless identified by a pass through code, are included in the bundled payment rate. When using the UB 2004 form it is advised that there be a specific line item indicating the XPANSION Procedure including a specific charge for the XPANSION procedure. The following Revenue Codes may be used to help capture the actual use and billing of the XPANSION System. This process will aid our request for a pass through code and could over time increase the reimbursement for those associated CPT codes. Revenue code 0272 Sterile Medical Supply Revenue code 0278 Medical Surgical Supplies, other implants Revenue code 0361 Minor surgical procedure Revenue code 0369 Other minor surgical procedure Revenue code 0761 Treatment room, clinic The line of with the revenue code should include the name of the specific product allowing the unique implantation of the tissue and a charge. The charge is an example only. All hospital product charges must consider the cost to charge ratio used in determining payment. For example if the line item charge is Phase I Coding Assessment for XPansion Page 3

$1,000 then the actual payment would be $320.00. If the acquisition cost of an item were $250 then to receive at least an equivalent amount the line item charge would need to be at least $781.25. Example for coding on a UB 2004 Hospital Outpatient Claim Form Rev Code 0278 XPANSION System $950.00 [Example charge for the line item] Procedure CPT codes are required to be reported on the same claim as the XPANSION System Table 2 Ambulatory Classification for CPT codes Describing the Procedure CPT APC CI SI Relative Weight Rate Minimum Unadjusted Copayment 15002 0135 T 4.965 $347.63 $69.53 +15003 0135 T 4.965 $347.63 $69.53 15004 0134 CH T 3.2535 $227.8 $45.56 +15005 0135 T 4.965 $347.63 $69.53 15040 0134 T 3.2535 $227.8 $45.56 15050 0134 CH T 3.2535 $227.8 $45.56 15100 0137 T 21.3126 $1,492.22 $298.45 +15101 0137 T 21.3126 $1,492.22 $298.45 15120 0137 T 21.3126 $1,492.22 $298.45 +15121 0137 T 21.3126 $1,492.22 $298.45 17999 0012 T 0.3874 $27.12 $5.48 Phase I Coding Assessment for XPansion Page 4

Table 3 reflects the assignment of the specific CPT codes to ASC groups. The grouping of a surgical procedure results in a bundled payment. The cost of surgical devices included in the procedure, unless identified by a pass through code, are included in the bundled payment rate. The payment is subject to multiple procedure discounting therefore the payment when 2 or more codes are on the same claim reflects 50% of the amount shown under the column for Final for the Calendar Year 2012. Table 3 Ambulatory Surgical Center for Selected CPT Codes CPT ASC Subject To Multiple Procedure Discounting Final CY 2012 Indicator Final CY 2012 Weight Final CY 2012 15002 Y A2 4.7053 $ 200.57 +15003 Y A2 4.7053 $ 200.57 15004 Y A2 3.0833 $ 131.43 +15005 Y A2 4.7053 $ 200.57 15040 Y A2 3.0833 $ 131.43 15050 Y A2 3.0833 $ 131.43 15100 Y A2 20.198 $ 860.98 +15101 Y A2 20.198 $ 860.98 15120 Y A2 20.198 $ 860.98 +15121 Y A2 20.198 $ 860.98 Phase I Coding Assessment for XPansion Page 5

Table 4 Represents the Medical Severity -Diagnosis Related Group (MS-DRG) that could be assigned to a procedure using the XPANSION System for autologous skin grafting. Assignment of an MS-DRG is based upon the combination of ICD-9-CM diagnosis and procedure codes, therefore the list provided is expansive and may not apply in all cases. MS-DRG payment is specific for patients that have been formally admitted to the hospital. Hospital admission includes an order by a physician that the patient is to be admitted for a treatment of a medical condition that cannot be properly medically managed in an outpatient setting. The patient will be assigned to a room and there will be room and board charges on their insurance claim. The estimated payment does not reflect hospital specific MS-DRG payment rates, the large urban teaching labor cost, the graduate medical education add on, or the additional payment for disproportionate share of low income patients. This is just an average reflecting the 2012 hospital payment update, therefore most hospital MS-DRG payment should be higher that our estimates. Billing for the XPANSION System for a hospital inpatient stay would be reported using the Revenue Codes as provide for hospital outpatient billing. They use the same UB 2004 form. Table 4 MS-DRG Reflecting the Reimbursement to the Hospital for the Inpatient Admission MS- DRG TYPE MS-DRG Title Relative Weighs 463 SURG WND DEBRID & SKN GRFT EXC HAND, FOR MUSCULO-CONN TISS DIS W MCC 464 SURG WND DEBRID & SKN GRFT EXC HAND, FOR MUSCULO-CONN TISS DIS W CC 465 SURG WND DEBRID & SKN GRFT EXC HAND, FOR MUSCULO-CONN TISS DIS W/O CC/MCC Arithmetic mean LOS Reimbursement Estimate $5631.16 5.0438 14.7 $28,402 2.9658 8.5 $16,701 1.7406 4.8 $9,802 570 SURG SKIN DEBRIDEMENT W MCC 2.5158 10.1 $14,167 571 SURG SKIN DEBRIDEMENT W CC 1.5427 6.9 $8,687 572 SURG SKIN DEBRIDEMENT W/O CC/MCC 0.9872 4.7 $5,559 573 SURG SKIN GRAFT FOR SKIN ULCER OR CELLULITIS W MCC 574 SURG SKIN GRAFT FOR SKIN ULCER OR CELLULITIS W CC 575 SURG SKIN GRAFT FOR SKIN ULCER OR CELLULITIS W/O CC/MCC 576 SURG SKIN GRAFT EXC FOR SKIN ULCER OR CELLULITIS W MCC 577 SURG SKIN GRAFT EXC FOR SKIN ULCER OR CELLULITIS W CC 578 SURG SKIN GRAFT EXC FOR SKIN ULCER OR CELLULITIS W/O CC/MCC 3.4249 12.5 $19,286 2.6984 10.8 $15,195 1.2271 5.2 $6,910 3.4936 10.7 $19,673 1.8118 5.8 $10,203 1.0684 3.1 $6,016 579 SURG OTHER SKIN, SUBCUT TISS & BREAST PROC W 2.6935 9.7 $15,168 MCC 580 SURG OTHER SKIN, SUBCUT TISS & BREAST PROC W CC 1.4801 5.1 $8,335 581 SURG OTHER SKIN, SUBCUT TISS & BREAST PROC W/O CC/MCC 0.9497 2.4 $5,348 Phase I Coding Assessment for XPansion Page 6

622 SURG SKIN GRAFTS & WOUND DEBRID FOR ENDOC, NUTRIT & METAB DIS W MCC 623 SURG SKIN GRAFTS & WOUND DEBRID FOR ENDOC, NUTRIT & METAB DIS W CC 624 SURG SKIN GRAFTS & WOUND DEBRID FOR ENDOC, NUTRIT & METAB DIS W/O CC/MCC 3.8339 13.9 $21,589 1.8542 7.6 $10,441 0.9965 4.3 $5,611 904 SURG SKIN GRAFTS FOR INJURIES W CC/MCC 3.1057 10.7 $17,489 905 SURG SKIN GRAFTS FOR INJURIES W/O CC/MCC 1.1702 4.5 $6,590 906 SURG HAND PROCEDURES FOR INJURIES 1.0566 3.3 $5,950 927 SURG EXTENSIVE BURNS OR FULL THICKNESS BURNS W MV 96+ HRS W SKIN GRAFT 928 SURG FULL THICKNESS BURN W SKIN GRAFT OR INHAL INJ W CC/MCC 929 SURG FULL THICKNESS BURN W SKIN GRAFT OR INHAL INJ W/O CC/MCC 12.1033 27.3 $68,156 4.8909 15.3 $27,541 2.1779 7.2 $12,264 Phase I Coding Assessment for XPansion Page 7