Corporate Compliance

Q&A: What is an invasive procedure?

Compliance Monitor, April 29, 2009

Q: What is an invasive procedure?

A: On January 15, CMS announced three national coverage determinations (NCD) that don’t cover surgeries but, rather, surgical and other invasive procedures. CMS made this move intentionally. The agency’s decision memos for the three NCDs—which offer a behind-the-scenes look at CMS’ rationale for each—state that the use of the word “surgery” could result in the need to modify past Medicare policies and procedures that included the term. Instead, CMS altered the wording slightly.

CMS defines surgical and other invasive procedures as “operative procedures in which skin or mucous membranes and connective tissue are incised, or an instrument is introduced through a natural body orifice.” Invasive procedures encompass a range of services, including: 
  • Minimally invasive dermatological procedures (e.g., biopsy, excision, or deep cryotherapy for malignant lesions)
  • Extensive multi-organ transplantation
  • All procedures in the surgery section of the CPT
  • Procedures such as percutaneous transluminal angioplasty and cardiac catheterization
  • Minimally invasive procedures involving biopsies or placement of probes or catheters requiring entry into a body cavity through a needle or trocar 
CMS also notes that invasive procedures exclude the “use of instruments such as otoscopes for examinations or very minor procedures such as drawing blood.”
This question and answer is adapted from the article “Understand how never events, HACs differ” which appeared in the May issue of the HCPro newsletter Healthcare Auditing Strategies. To learn more about this newsletter visit the HCMarketplace.

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