Unless you write into your commercial contracts that the $2,500 or more that an eye bank will charge you for harvesting corneal tissue is in addition to the facility fee, corneal transplantation isn't feasible in the ASC setting. Medicare has a pass-through provision, but if you don't carve out implants such as transplants with your private payors, you're basically prevented from doing corneal transplants in a surgery center. As you'll see, the key to getting reimbursed for corneal tissue procurement, processing and distribution is HCPCS code V2785, which should be reimbursed as an add-on to your ASC facility fee.

V2785, the secret add-on
When you perform a procedure involving corneal tissue, here's what to do: Bill your Part B Medicare Carrier one of the line items listed in "Billing for Corneal Transplants" below and another line item using V2785 for the corneal tissue.

Facility reimbursement will be equal to the amount for the appropriate procedure as listed, plus an additional amount for the "processing, preserving and transporting of corneal tissue" (code V2785). The reimbursement shouldn't be subject to multiple procedure discounting.

You must support claims for code V2785 with a copy of the invoice from the supplying eye bank showing the actual cost incurred to acquire, process and transport the specific corneal tissue used for the patient. Different eye banks charge different amounts; if tissue is imported from another eye bank, the transportation fee may be somewhat higher. If an eye bank increases the processing fee when it prepares pre-cut donor corneas for DSEK (Descemet's stripping with endothelial keratoplasty), you should be able to pass on this increase in fee to Medicare because Medicare is reimbursing for the tissue, processing and transportation. If, however, the surgeon prepares the tissue for DSEK in the ASC, then there is no way to reimburse the surgeon for the preparation of that tissue. Any preparation done by the surgeon would be considered bundled within his global surgeon fee. Keep eye bank invoices on file and available for carrier review for verification purposes.

Reimbursement roadblocks
Some commercial carriers may pose more of a dilemma regarding corneal tissue costs. Ideally, all commercial carrier contracts would pay for corneal tissue at a pass-through rate like Medicare. Unfortunately, unless you've written your contracts correctly, commercial carriers pay for corneal tissue in whatever way they deem fit. Before you consider doing any corneal transplant procedures, you need to review and perhaps revise your contracts.

Your commercial carriers might reimburse tissue as Medicare does, using the separate HCPCS code V4275. They may want to carve out or increase your reimbursement for the specific procedure code and not pay it as a separate line item, or they may refuse to pay for any implants — including corneal tissue.

While the cost reimbursement method is obviously the best scenario to protect an ASC from price increases, some commercial contractors won't do this. If you have to sign a contract with a carve-out rate for corneal procedures, make sure you set the carve out high enough to cover the cost, and ask for a price escalation clause, which protects you if the eye bank raises the price of tissue before the term of the contract ends. If the payor refuses to pay for it at all, either don't sign the contract or don't perform procedures requiring corneal tissue.