CMS comparative billing reports: What you need to know

October 30, 2015
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Some doctors may receive a report from the Centers for Medicare & Medicaid Services (CMS) that provides data on provider billing patterns, and AOA stands ready for doctors' questions.

Called comparative billing reports (CBRs), these educational tools administered by CMS—and disseminated under contract by federal services firm eGlobalTech—are not punitive, but instead offer doctors insight into billing trends across regions and policy groups.

On Oct. 26, 2015, CMS issued CBRs to about 6,500 doctors of optometry, providing information about their own billing patterns for general ophthalmological services, evaluation and management (E&M) services, and/or diagnostic imaging services, as well as the billing and payment patterns of their peers, both nationally and across their state.

According to eGlobalTech, CBR analyses will include Current Procedural Terminology® (CPT) codes: 92002, 92004, 92012, 92014, 92081, 92082, 92083, 92133, 92134, 99201-99205, and 99211-99215.

The CBRs display the ratio that doctors of optometry bill eye codes 92004 and 92014, compared to 92002 and 92012. The national averages are 91% (92004) and 74% (92014), while state averages also are provided for comparison. The CBRs also report estimated time for E&M visits 99201-99215 with doctors' of optometry national averages at 36.4 minutes for new patients and 17.4 minutes for established patients.

Some doctors of optometry who have received CBRs have already contacted the AOA regarding questions with this particular data set. While having higher than average time spent with patients may make a doctor an outlier, this is not intended to be perceived negatively. In fact many patients may view having additional time with their physician as a positive. The overall value of this particular comparative data is questionable.

Finally, CBRs also report % of glaucoma patients who received vision fields 92082-83 and scanning laser imaging codes 92113-14 within 90 days. The national average is 37%.

This data gives providers an opportunity to compare themselves to their peers, check their records against CMS' data and review Medicare guidelines to ensure compliance. CBRs do not identify overpayments.

Reports are only accessible to the doctors who receive them; they are not publicly available. Recipients were selected by an analysis of data from claims paid by traditional fee-for-service Medicare that identified them as having different billing patterns when compared with peers. The analyses are based on data extracted from the CMS Integrated Data Repository with the latest version of claims as of Oct. 1, 2015. The data includes claims with dates of service from July 1, 2014, to June 30, 2015.

Doctors can expect CBRs to either be faxed or mailed.

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