Knowledge Base Article

Did You Know?

June is cataract awareness month and according to the National Eye Institute (link), most cataracts are age-related, there are no early symptoms of cataracts and later symptoms includes blurry vision, colors that seem faded, sensitivity to light, trouble seeing at night and double vision.

A cataract is diagnosed by a dilated eye exam and the treatment is surgery. Cataract surgery is one of the most common operations in the United States. In fact, more than half of all Americans aged eighty or older either have cataracts or have had surgery to get rid of cataracts.

Why it Matters?

Being a high-volume surgery, means scrutiny by CMS and Medicare Contractors to assure documentation in the medical record supports medical necessity of the procedure.

Recovery Audit Contractors

RAC Issue 0002 cataract removal (link) has been an approved complex review for procedures performed in the outpatient hospital setting and ambulatory surgery centers (ASCs) since February 1, 2017. RACs will review documentation to determine if cataract surgery meets Medicare coverage criteria, meets applicable coding guidelines, and/or is medically reasonable and necessary. Applicable National Coverage Determinations (NCDs), Local Coverage Determinations (LCDs), and Local Coverage Articles (LCAs) are included in this RAC issue webpage.

Comprehensive Error Rate Testing (CERT)

In the 2021 CERT Medicare Fee-for-Service supplemental improper payment report, cataract removal and lens insertion is listed in Table D1: Top 20 Service Types with Highest Improper Payments: Part B (link).

The improper payment rate for this surgery was 12.7%. The CERT cites two types of errors, insufficient documentation, and incorrect coding, as being the cause of improper payments. Specifically, the insufficient documentation project improper payment was $190,495,888 and the incorrect coding improper payment was $27,844,602.

Medicare Administrative Contractors (MACs)

Jurisdiction 15 (J15) MAC: CGS

Prior to the COVID-19 public health emergency, the J15 MAC CGS’ Targeted Probe and Educate (TPE) activities included cataract removal reviews. Their last results posted (link) was for reviews completed from January 1, 2020, through March 31, 2020, with a claim error rate in Ohio of 30.8%.

CGS’ review results list documentation that should be included to prevent denials. CGS has also published an cataract extraction with intraocular lens ADR checklist (link) for providers who are submitting medical records for review.

JF MAC: Noridian

In May 2021, Noridian, published a notification of their intent to perform a service specific targeted review of cataract removal (link). Noridian published review findings in November and December of 2021.

The review of claims for Arizona, Utah, Montana, North Dakota, South Dakota, and Wyoming included claims from May 3, 2021, through October 26, 2021. The overall claims error rate was 26.6% and payment error rate was 27%.

Their review of claims for Alaska, Idaho, Oregon, and Washington included claims from May 3, 2021, through November 16, 2021. The overall claim error rate was 71.3% and payment error rate was 70.5%.

In both reviews, claims were denied for the following two reasons:

• Documentation was not received timely in response to the additional documentation request (ADR), and
• Documentation did not support medical necessity per LCD requirements.

Noridian’s review results articles includes provider education detailing under what circumstances the surgery would be considered medical necessary and the required medical record documentation to support medical necessity.

Noridian also cites the 45-calendar day requirement for timely submission of documentation by providers.

Supplemental Medical Review Contractor (SMRC)

On February 16, 2022, the SMRC published a notification of their intent to review cataract surgeries performed in the physician office, outpatient hospital and specialty facility clinical access hospitals (link). In the background section of the notification, they note that “this type of surgery has been a topic of interest for the Office of Inspector General (OIG) for a number of years. The OIG looked into surgery in both the outpatient facility and ambulatory service center settings. CMS data reflects a potential vulnerability.”

What Can You Do?

With so many entities focused on reviewing cataract surgery claims, moving forward providers should:

• Respond to ADRs in a timely manner,
• Become familiar with medical necessity indications and documentation requirements detailed in Medicare coverage documents (NCDs, LCDs, LCAs),
• Be aware of who is performing cataract surgery reviews,
• Read published review results to understand reasons for denials and ways to prevent future denials, and
• Ensure physicians performing these procedures are also aware of Medicare coverage requirements.