OIG Adds Lower Extremity Revascularization Procedures to 2025 Work Plan

OIG Adds Lower Extremity Revascularization Procedures to 2025 Work Plan

StreamlineMD’s January 2024 blog discussed the top five denials for Interventional Radiology. One of those topics was diagnostic angiography during therapeutic treatment, which continues to be a hot topic. And now the OIG is adding Lower Extremity Revascularization procedures to its 2025 work plan.

Increased OIG Scrutiny

  • The lower extremity revascularization procedures, CPTs 37220-37235 and 0234T-0238T, have been assigned to the OIG work plan for 2025.
  • In CY 2022 and 2023, Medicare paid approximately $1.16 billion for these procedures performed in the office setting.
  • CMS and whistleblower fraud reporting have identified these procedures as vulnerable to improper payments.
  • The OIG will analyze these specific procedures for program integrity, waste, fraud, and abuse. No other details regarding the work plan’s focus have been provided.

More Insurance Denials

  • Commercial Insurance carriers have recently begun to deny these claims and recoup prior payments going back to 2022.
  • The coding guidelines for these procedures are according to authoritative entities in order of pertinence and should be taken under advisement.
  • Insurance carriers regularly deny unilateral and bilateral extremity angiography codes when billed with lower extremity revascularization procedures, especially when documentation does not meet medical necessity.
CPTDescriptionwRVUOBL MC Average Allowable
75710Angio Extremity Unilateral1.75$149.79
75716Angio Extremity Bilateral1.97$162.44
+76937US Guidance Vascular Access0.3$38.28
  • Insurance carriers often scrutinize vascular US guidance code 76937, which has 0.3 wRVU and four coding elements:
    • Evaluation of potential sites
    • Vessel patency
    • Visualization of needle entry
    • Permanent saved image) elements
  • These elements are not a CPT or CMS documentation requirement but are often denied by carriers when absent from the report.
  • Insurance carriers used algorithms before implementing AI to search requested records for documentation deficiencies and quickly deny the claim. This delays reimbursement and the amount of work needed to secure provider payment.

Not Worth the Risk

  • When comparing larger wRVUs for the lower extremity arteriograms in comparison to vascular US guidance, the target and risk are larger and higher.
  • Failing a CMS audit can result in fines up to three times the total damages and extrapolated up to 10 years.

Understanding the Difference Between Roadmapping versus Diagnostic Angiography

Diagnostic angiography:

  • Means the disease is being diagnosed.
  • If the patient has known PAD, describing the degree of disease in each vessel while determining the area(s) to treat is not considered a diagnostic angiography and not a billable service.

Roadmapping:

  • Typically performed before any vascular therapy to determine where to treat which is often mistaken for diagnostic angiography.
  • Documenting the imaging findings does not equate to a billable service unless one of the criteria is met and clearly documented in the report.

CMS Guidance

  • CMS added language in 2023 regarding diagnostic angiography at the same time as a therapeutic treatment:
  • NCCI Manual Ch 5 D13, effective 1/1/2023: Open and percutaneous interventional vascular procedures include operative angiograms and/or venograms which shall not be separately reported as diagnostic angiograms/venograms. The “CPT Manual” describes the circumstances under which a provider/supplier may separately report a diagnostic angiogram/venogram at the time of an interventional vascular procedure. A diagnostic angiogram/venogram may be separately reportable with modifiers 59 or XU. The provider/supplier shall not separately report a diagnostic angiography code. If a diagnostic angiogram (fluoroscopic or computed tomographic) was performed before the date of the open or percutaneous intravascular interventional procedure, a second diagnostic angiogram cannot be reported on the date of the open or percutaneous intravascular interventional procedure unless it is medically reasonable and necessary to repeat the study to further define the anatomy and pathology.”

AMA/CPT Rules

  • The AMA/CPT and CMS have clear instructions on the documentation requirements to bill for diagnostic angiography during therapeutic treatment.
  • The four criteria to meet medical necessity along with a statement of treatment decision was based upon the angiographic findings.
    • No prior study available
    • Change in patient’s condition since prior study
    • Inadequate visualization of anatomy
    • A clinical change in the patient during the procedure
  • Insurance companies are enforcing this by denying angiography services when documentation requirements are not met.

SIR Coding Guidelines for Lower Extremity Revascularization CPT Codes

  • “These codes take into account the fact that multiple techniques may be needed to open areas of disease in some vessels and that these interventions may take place in different vascular territories. In general, the codes for interventions progress up a hierarchy of intensity with the work of the less-intense intervention included in the higher-intensity code. For example, angioplasty before a stent placement would be a progression up this hierarchy and only the stent code would be reported. Each of these codes includes the work of accessing the artery, selecting the vessel, crossing the lesion, interpreting the images, performing therapeutic intervention(s) in the entire vessel segment,using any embolic protection device, performing final image interpretation, and closing the arteriotomy by any method.”

What Does This Mean for Providers?

  • Diagnostic angiography should not be routinely billed with every lower extremity revascularization procedure or any other therapeutic service unless meeting one of the four criteria and clearly documenting such in the report.
  • Do not confuse roadmapping for diagnostic angiography.
  • The inclusion of these procedures into the OIG work plan signals a need for heightened attention to compliance and accurate billing practices.
  • Following CMS coding and billing guidelines is considered industry best practice.
  • Review existing templates and update them as appropriate.
  • Aligning with CPT descriptions helps eliminate confusion for coders, billers, and insurance companies.
  • Patients are increasingly accessing their medical records and closely reviewing their bills. This heightened awareness emphasizes the importance of clear and accurate documentation to ensure transparency and trust in our healthcare services.

References: AMA/CPT, SIR, CMS, and OIG

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Cyber Incident Update – 9/28/25 at 6:00 pm EST:

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We are pleased to inform you that, following clearance from our cybersecurity experts, client access to our system has been restored. You may begin accessing the system starting at 6:00 PM EST today, Sunday, September 28, 2025.

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Cyber Incident Update – 9/28/25 at 2:00 pm EST:

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Cyber Incident Update – 9/28/25 at 12:00 pm EST:

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Cyber Incident Update – 9/27/25 at 10:00 pm EST:

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At this stage, we are awaiting final clearance from our cybersecurity partner before restoring client access.

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Cyber Incident Update – 9/27/25 at 7:00 pm EST:

We are continuing to move forward with final preparations for restoring system access. Our internal teams have completed their validation processes, and the environment remains fully operational.

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As always, we are taking every measure to ensure a secure and controlled restoration.

Thank you again for your continued patience and support. Our next update will be provided by 10:00 PM EST.

Cyber Incident Update – 9/27/25 at 11:00 am EST:

We are pleased to share that our team has gained access to the system environment and is actively conducting testing—an important step toward the full restoration of services.

As part of this process, we have completed testing of the Practice Management (PM) and Coding software and are pleased to report that no issues have been identified with the software. Testing will continue across all system components to ensure overall stability and reliability.

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Cyber Incident Update – 9/26/25 at 7:00 pm EST:

We are pleased to share that our team is now gaining access to the system environment and actively conducting testing. This is an important step toward full restoration of services.

We again want to reassure you that there is no evidence of any compromise of Protected Health Information (PHI) or damage to our systems.

Our teams will continue to work throughout the evening and into the weekend to validate all aspects of the system before bringing it back online.

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We will provide another update at 10:00 am EST on Saturday, September 27, 2025.

Cyber Incident Update – 9/26/25 at 3:00 pm EST:

We continue to make steady progress in our restoration efforts. At this time, 95% of servers have been cleared; however, they remain behind protective firewalls as we work closely with our team of experts toward full restoration.

The StreamlineMD systems will remain unavailable for the rest of today, Friday, September 26, 2025. Our teams will begin comprehensive testing of all aspects of the system as soon as possible, likely this evening and over the weekend.

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We will provide another update at 6:00 pm EST.

Cyber Incident Update – 9/26/25 at 2:00 pm EST:

We continue to work diligently this afternoon with our cybersecurity team and are making steady progress.   

We anticipate the StreamlineMD systems will remain inaccessible for the remainder of today, Friday, September 26, 2025.  

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Cyber Incident Update – 9/26/25 at 11:00 am EST:

We continue to work throughout the day with our cybersecurity team and continue to make progress.  

We anticipate the StreamlineMD systems will not be accessible before 3:00 pm EST on Friday, September 26, 2025

We will provide another update at 2:00 pm EST.

We appreciate your continued patience and understanding as we work to restore services in a secure and controlled manner.

Cyber Incident Update – 9/26/25 at 09:00 am EST:

We continue to work this morning with our cybersecurity team and continue to make progress.   

We still don’t anticipate StreamlineMD systems to be fully operational before 12:00 pm EST on Friday, September 26, 2025.  

We will provide another update at 12:00 pm EST.

We appreciate your continued patience and understanding as we work to restore services in a secure and controlled manner.

Cyber Incident Update – 9/26/25 at 07:00 am EST:

We have continued to work through the night with our cybersecurity team and continue to make progress.  

We will continue restoring servers to service and testing internally. 

We still don’t anticipate StreamlineMD systems to be fully operational before 12:00 pm EST on Friday, September 26, 2025. 

We will provide another update at 9:00 am EST.

We appreciate your continued patience and understanding as we work to restore services in a secure and controlled manner.

Cyber Incident Update – 9/25/25 at 11:00 pm EST:

So far, we are making great progress, and our systems are internally coming back online. At this time, there is no evidence of system damage or PHI compromise.

Throughout the night, we will continue restoring servers to service and testing internally.

We don’t anticipate StreamlineMD systems to be fully operational before 12:00 pm EST on Friday, September 26, 2025.

We will provide another update on Friday, September 26, at 6:00 am EST


Cyber Incident Update –9/25/25 at 7:00 pm EST:

We are currently in the process of restoring our servers and anticipate determining a timeline for resuming full operations by 10:00 PM EST this evening, September 25, 2025.

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Incident Update – 9/25/25 at 12:00 pm EST:

StreamlineMD is currently working closely with our security team to address a cybersecurity incident that occurred during the overnight hours of September 24, 2025. As a precautionary measure, we proactively shut down our systems to prevent any potential data compromise.

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