[Federal Register: June 29, 2006 (Volume 71, Number 125)]
[Notices]
[Page 37169-37430]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr29jn06-109]
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Part II
Department of Health and Human Services
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Centers for Medicare & Medicaid Services
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Medicare Program; Five-Year Review of Work Relative Value Units Under
the Physician Fee Schedule and Proposed Changes to the Practice Expense
Methodology; Notice
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
[CMS-1512-PN]
RIN 0938-AO22
Medicare Program; Five-Year Review of Work Relative Value Units
Under the Physician Fee Schedule and Proposed Changes to the Practice
Expense Methodology
AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS.
ACTION: Proposed notice.
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SUMMARY: This proposed notice sets forth proposed revisions to work
relative value units (RVUs) affecting payment for physicians' services.
The statute requires that we review RVUs no less often than every 5
years. This is our third review of work RVUs since we implemented the
physician fee schedule (PFS) on January 1, 1992. These revisions to
work RVUs are proposed to be effective for services furnished beginning
January 1, 2007. These revisions reflect changes in medical practice,
coding changes, new data on relative value components, and the addition
of new procedures that affect the relative amount of physician work
required to perform each service as required by the statute. In
addition, we are proposing revisions to our methodology for calculating
practice expense (PE) RVUs, including changes based on supplemental
survey data for PE. This revised methodology would be used to establish
payment for services beginning January 1, 2007.
DATES: To be assured consideration, comments must be received at one of
the addresses provided below, no later than 5 p.m. on Monday, August
21, 2006.
ADDRESSES: In commenting, please refer to file code CMS-1512-PN.
Because of staff and resource limitations, we cannot accept comments by
facsimile (FAX) transmission.
You may submit comments in one of four ways (no duplicates,
please):
1. Electronically. You may submit electronic comments on specific
issues in this regulation to http://www.cms.hhs.gov/eRulemaking. Click
on the link ``Submit electronic comments on CMS regulations with an
open comment period.'' (Attachments should be in Microsoft Word,
WordPerfect, or Excel; however, we prefer Microsoft Word.)
2. By regular mail. You may mail written comments (one original and
two copies) to the following address ONLY:
Centers for Medicare & Medicaid Services, Department of Health and
Human Services, Attention: CMS-1512-PN, P.O. Box 8014, Baltimore, MD
21244-8014.
Please allow sufficient time for mailed comments to be received
before the close of the comment period.
3. By express or overnight mail. You may send written comments (one
original and two copies) to the following address ONLY:
Centers for Medicare & Medicaid Services, Department of Health and
Human Services, Attention: CMS-1512-PN, Mail Stop C4-26-05, 7500
Security Boulevard, Baltimore, MD 21244-1850.
4. By hand or courier. If you prefer, you may deliver (by hand or
courier) your written comments (one original and two copies) before the
close of the comment period to one of the following addresses. If you
intend to deliver your comments to the Baltimore address, please call
telephone number (410) 786-7195 in advance to schedule your arrival
with one of our staff members.
Room 445-G, Hubert H. Humphrey Building, 200 Independence Avenue,
SW., Washington, DC 20201; or 7500 Security Boulevard, Baltimore, MD
21244-1850.
(Because access to the interior of the HHH Building is not readily
available to persons without Federal Government identification,
commenters are encouraged to leave their comments in the CMS drop slots
located in the main lobby of the building. A stamp-in clock is
available for persons wishing to retain a proof of filing by stamping
in and retaining an extra copy of the comments being filed.)
Comments mailed to the addresses indicated as appropriate for hand
or courier delivery may be delayed and received after the comment
period.
For information on viewing public comments, see the beginning of
the SUPPLEMENTARY INFORMATION section.
FOR FURTHER INFORMATION CONTACT: Diane Milstead, (410) 786-3355, or
Gaysha Brooks, (410) 786-9649
SUPPLEMENTARY INFORMATION: Submitting Comments: We welcome comments
from the public on the proposed work RVUs set forth in Addendum C, the
proposed practice expense methodology, and other issues set forth in
this proposed notice to assist us in fully considering issues and
developing policies. You can assist us by referencing the file code
CMS-1512-PN and the specific ``issue identifier'' that precedes the
section on which you choose to comment.
Inspection of Public Comments: All comments received before the
close of the comment period are available for viewing by the public,
including any personally identifiable or confidential business
information that is included in a comment. We post all comments
received before the close of the comment period on the following Web
site as soon as possible after they are received: http://www.cms.hhs.gov/eRulemaking.
Click on the link ``Electronic Comments on
CMS Regulations'' on that Web site to view public comments.
Comments received timely will be available for public inspection as
they are received, generally beginning approximately 3 weeks after
publication of a document, at the headquarters of the Centers for
Medicare & Medicaid Services, 7500 Security Boulevard, Baltimore,
Maryland 21244, Monday through Friday of each week from 8:30 a.m. to 4
p.m. To schedule an appointment to view public comments, phone 1-800-
743-3951.
Information on the PFS can be found on the CMS homepage. You can
access this data by using the following directions:
1. Go to the following Web site http://www.cms.hhs.gov/PhysicianFeeSched/
.
2. Select ``Physician Fee Schedule Federal Regulation Notices.''
To assist readers in referencing sections contained in this
preamble, we are providing the following table of contents.
Table of Contents
I. Background
A. Legislative History
B. Published Changes to the Physician Fee Schedule
C. Current Proposed Notice
D. The 5-Year Review Process
II. Discussion of Comments and Decisions
A. Review of Comments
B. Discussion of Comments by Clinical Area
1. Dermatology and Plastic Surgery
2. Orthopedic Surgery
3. Gynecology, Urology, Pain Medicine, and Neurosurgery
4. Radiology, Pathology, and Other Miscellaneous Services
5. Evaluation and Management Services
6. Cardiothoracic Surgery
7. General, Colorectal and Vascular Surgery
8. Otolaryngology and Ophthalmology
9. HCPAC Codes
C. Other Issues Under the 5-Year Review
1. Anesthesia Services
2. Discussion of Post-Operative Visits Included in the Global
Surgical Packages
3. Codes Referred to CPT Editorial Panel from Five-Year Review
of Work Relative Value Units
4. Budget Neutrality
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5. Effect on Practice Expense Inputs Stemming From the 5-Year
Review
6. Nature and Format of Comments on Work RVUs
D. Resource-Based Practice Expense (PE) RVUs
1. Current Methodology
2. PE Proposed Methodology for CY 2006
3. Modifications to PE Proposals
III. Collection of Information Requirements
IV. Response to Comments
V. Regulatory Impact Analysis
Addendum A: Explanation and Use of Addendum B
Addendum B: Relative Value Units and Related Information
Addendum C: Codes With Work RVUs Subject to Comment
In addition, because of the many organizations and terms to
which we refer by acronym in this proposed notice, we are listing
these acronyms and their corresponding terms in alphabetical order
below:
AAD American Academy of Dermatology
AAN American Academy of Neurology
AANEM American Association of Neuromuscular and Electrodiagnostic
Medicine
AAFP American Academy of Family Physicians
AAGP American Association for Geriatric Psychiatry
AAHCP American Academy of Home Care Physicians
AANS American Association of Neurological Surgeons
AAO American Academy of Ophthalmology
AAO-HNS American Academy of Otolaryngology-Head and Neck Surgery
AAOA American Academy of Otolaryngic Allergy
AAOS American Academy of Orthopaedic Surgeons
AAP American Academy of Pediatrics
AAPM American Academy of Pain Medicine
AAPMR American Academy of Physical Medicine and Rehabilitation
AATS American Association for Thoracic Surgery
ACC American College of Cardiology
ACG American College of Gastroenterology
ACNS American Clinical Neurophysiology Society
ACOG American College of Obstetricians and Gynecologists
ACR American College of Radiology
ACS American College of Surgeons
AFROC Association of Freestanding Radiation Oncology Centers
AGA American Gastroenterological Association
AGS American Geriatric Society
AK Actinic keratoses
AMA American Medical Association
AMDA American Medical Directors Association
AOA American Optometric Association
ASA American Society of Anesthesiologists
ASC Ambulatory surgical center
ASCRS American Society of Colon and Rectal Surgeons
ASGE American Society of Gastrointestinal Endoscopy
ASHA American Speech-Language-Hearing Association
ASPS American Society of Plastic Surgeons
ASSH American Society for Surgery of the Hand
ASTRO American Society for Therapeutic Radiology and Oncology
AUA American Urological Association
BBA 97 Balanced Budget Act of 1997 (Pub. L. 105-33)
BBRA [Medicare, Medicaid and State Child Health Insurance Program]
Balanced Budget Refinement Act of 1999 (Pub. L. 106-113)
BNF Budget neutrality factor
CAPU Coalition for the Advancement of Prosthetic Urology
CF Conversion factor
CNS Congress of Neurological Surgeons
CPEP Clinical Practice Expert Panels
CPT Current Procedural Terminology
CY Calendar year
DRG Diagnosis-Related Group
E/M Evaluation and management
FR Federal Register
HCPAC Health Care Professionals Advisory Committee
HCPCS Healthcare Common Procedure Coding System
HHS Health and Human Services
ICU Intensive care unit
IDTF Independent diagnostic testing facility
IWPUT Intra-service work per unit of time
JCAAI Joint Council of Allergy, Asthma, and Immunology
MMA Medicare Prescription Drug, Improvement, and Modernization Act
of 2003 (Pub. L. 108-173)
MMSV Minimum multi-specialty visit
MPC [the RUC's] Multi-Specialty Points of Comparison
NCQDIS National Coalition of Quality Diagnostic Imaging Services
NPWP Non-physician work pool
NSQIP National Surgical Quality Improvement Program
PC Professional component
PE Practice Expense
PE/HR Practice expense per hour
PEAC Practice Expense Advisory Committee
PERC Practice Expense Review Committee
PFS Physician fee schedule
RFA Regulatory Flexibility Act
RIA Regulatory impact analysis
RN Registered nurse
RUC [AMA's Specialty Society] Relative [Value] Update Committee
RVU Relative value unit
SMS [AMA's] Socioeconomic Monitoring System
SNF Skilled nursing facility
STS Society of Thoracic Surgeons
SVS Society for Vascular Surgery
TC Technical component
VA [Department of] Veterans Affairs
I. Background
[If you choose to comment on issues in this section, please include
the caption ``BACKGROUND'' at the beginning of your comments.]
A. Legislative History
Since January 1, 1992, Medicare has paid for physicians' services
under section 1848 of the Social Security Act (the Act), ``Payment for
Physicians' Services.'' Section 1848 of the Act contains three major
elements: (1) A fee schedule for the payment of physicians' services;
(2) a sustainable growth rate for the rates of increase in Medicare
expenditures for physicians' services; and (3) limits on the amounts
that nonparticipating physicians can charge beneficiaries. The Act
requires that payments under the fee schedule be based on national
uniform relative value units (RVUs) based on the resources used in
furnishing a service. Section 1848(c) of the Act requires that national
RVUs be established for physician work, practice expense (PE), and
malpractice expense.
Section 1848(c)(2)(B)(ii)(II) of the Act provides that adjustments
in RVUs may not cause total physician fee schedule (PFS) payments for
the year to differ by more than $20 million from the amount that would
have been paid had the adjustments not been made. If this tolerance is
exceeded, we must make adjustments to the conversion factors (CFs) to
preserve budget neutrality.
B. Published Changes to the Physician Fee Schedule
On an annual basis, we publish regulations relating to updates to
the RVUs and revisions to the payment policies under the PFS. In the
Calendar Year (CY) 2006 Physician Fee Schedule final rule with comment
period that appeared in the Federal Register on November 21, 2005 (70
FR 70116) (hereinafter referred to as the CY 2006 PFS final rule with
comment period), we finalized the CY 2005 interim physician work RVUs,
issued new interim work RVUs for new and revised codes for CY 2006, and
finalized several other payment policies related to the PFS. This final
rule with comment also discussed the status of the third 5-Year Review
of work RVUs.
C. Current Proposed Notice
This proposed notice sets forth proposed revisions to work RVUs
affecting payment for physicians' services. Section 1848(c)(2)(B)(i) of
the Act requires that we review RVUs no less often than every 5 years.
We implemented the PFS effective for services furnished beginning
January 1, 1992. The first 5-Year Review of work was initiated in
December 1994 and was effective for services furnished beginning
January 1, 1997. The second 5-Year Review of work was initiated in
November 1999 and was effective for services furnished beginning
January 1 2002. The third 5-Year Review of work was initiated in
November 2004.
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Revisions of physician work RVUs proposed in this proposed notice are
subject to a 60-day public comment period. We will review public
comments, make adjustments to our proposals in response to comments, as
appropriate, and include revised values in our CY 2007 Physician Fee
Schedule final rule with comment period, effective for services
furnished beginning January 1, 2007.
D. The 5-Year Review Process
We initiated the third 5-Year Review by soliciting public comments
on potentially misvalued work RVUs for all services in the CY 2005
Physician Fee Schedule final rule with comment period that appeared in
the Federal Register on November 15, 2004 (69 FR 66370) and provided a
60-day comment period.
We received comments from approximately 35 specialty groups,
organizations, and individuals involving over 500 Current Procedural
Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS)
codes. As explained in the CY 2006 PFS final rule with comment period
(70 FR 70283), we shared these comments with the American Medical
Association (AMA) Specialty Society Relative Value Update Committee
(RUC). The RUC was formed in November 1991 and grew out of a series of
discussions between the AMA and major national medical specialty
societies. The work of the RUC is supported by the RUC Advisory
Committee, which is made up of representatives of 100 specialty
societies in the AMA's House of Delegates.
The RUC currently makes annual recommendations to us on RVUs for
new and revised CPT codes. The RUC also provided recommendations on
changes to the work RVUs for existing codes during the previous 5-Year
Reviews. We believe that the RUC's participation was beneficial because
the RUC is experienced in recommending RVUs for the codes that have
been added to or revised by the CPT Editorial Panel since we
implemented the PFS in 1992. By virtue of its multispecialty membership
and consultation with specialty societies, the RUC involves the medical
community in formulating its recommendations. For codes used primarily
by nonphysician practitioners, the Health Care Professionals Advisory
Committee (HCPAC), a companion to the RUC, has made recommendations to
us.
As we stated in the previous 5-Year Reviews, we retain the
responsibility for analyzing any comments and recommendations received,
developing the proposed rule, evaluating the comments on the proposed
rule, and deciding whether and how to revise the work RVUs for any
given service.
After we sent the RUC the comments we received on potentially
misvalued services, as well as a list of approximately 160 services
that we had identified as being potentially misvalued, the RUC
identified the specialty societies that expressed interest in making
presentations concerning those services. To prepare for presentations
to the RUC, most specialty societies compiled data using a standard
survey instrument whereby respondents compared the surveyed service
with similar ``reference'' services that have established, agreed upon
work values. Respondents were asked to estimate: the work for the
survey code; the time to perform the ``pre-'', ``intra-'', and ``post-
'' service activities; and the technical skill, risk, and judgment
involved with performing the service. Post-service activities were
broken down into hospital and office visits and were assigned an
appropriate evaluation and management (E/M) code by the respondent.
Each specialty society selected the physician sample that was surveyed.
A minimum of 30 responses was required by the RUC for the survey to be
considered adequate.
For this 5-Year Review, the RUC permitted a specialty society to
use a ``minisurvey'' for some codes if the number of codes a specialty
society was reviewing was extremely high. These minisurveys required
less information from the respondent, but were similar in design. In
addition, the RUC approved the use of information from the National
Surgical Quality Improvement Program (NSQIP) database and the Society
of Thoracic Surgeons (STS) national database in the valuation of some
services.
The NSQIP was started by the Department of Veterans Affairs (VA)
for quality improvement purposes in 1991 with 128 VA medical centers,
but now includes a large volume of surgical procedures from non-VA
medical centers as well. The total number of cases for VA and non-VA
medical centers is greater than one million. The NSQIP database
contains pre-, intra-, and post-operative data, including intra-service
times and length of stay data.
The STS National database is a voluntary reporting system for the
collection of outcomes data related to thoracic surgical services. This
database currently contains over two million patient records collected
from more than 450 practices (from 1995 through 2004). Over 70 percent
of the hospitals currently performing heart surgeries in the U.S.
reportedly participate in this database.
Some specialty societies used a ``building-block'' approach to
validate the survey results for surgical services. In constructing the
building blocks, a service is divided into pre-, intra-, and post-
service components. The pre-service component consists of all services
furnished before the physician makes the skin incision (for example,
pre-operative evaluation and scrubbing); the intra-service component
consists of the ``skin-to-skin'' time; and the post-service component
includes immediate post-surgery services and subsequent hospital and
office visits. Each component (or building block) is then assigned work
RVUs. Pre-service and intra-service work RVUs are based on time and the
intensity of the activities, and post-service work is based on the
specified E/M service for each post-operative visit. These three values
are then summed to compute ``building-block'' work RVUs.
The results of the surveys were reviewed and organized by the
specialty societies and then presented to the RUC. The RUC used eight
workgroups, comprised of RUC members, to evaluate a series of
clinically related codes based on the survey results and additional
discussion. The workgroups also evaluated the relative work (time and
intensity) for each service compared to other services on the fee
schedule. The workgroups submitted their recommendations to the full
RUC, which then considered the workgroup reports and then sent the
final RUC recommendations to us.
II. Discussion of Comments and Decisions
A. Review of Comments
As previously stated, we sent the RUC a list of codes for review.
The RUC submitted work RVU recommendations for these codes, with the
exception of the codes that were withdrawn or referred to the CPT
Editorial Panel for further review or action, and one CPT code (32020)
for which no specialty society expressed an interest in conducting a
survey. In the future, we will consider an alternative method to re-
evaluate codes when no specialties express an interest in conducting a
survey and we would appreciate suggestions from commenters on what
alternative methods could be used.
We analyzed all of the RUC recommendations by evaluating the
methodology used by each workgroup to develop the recommendations, the
recommended work RVUs, and the rationale for the recommendations.
[[Page 37173]]
When appropriate and feasible, if we had concerns about the application
of a particular methodology, we assessed whether the recommended work
RVUs were appropriate by using alternative methodologies.
In conducting our review of the RUC recommendations we considered
whether: (1) The code was part of a completed survey process; (2) the
methodology used by the specialty society followed the standard RUC
process; (3) the survey respondents stated the work had or had not
changed in the past 5 years; (4) databases (for example, STS, NSQIP,
and Medicare diagnosis-related group (DRG)) were used in lieu of the
standard RUC methodology or as a supplement to the standard
methodology; and (5) the intra-service work per unit of time (IWPUT)
calculation was used to determine work RVUs in lieu of the standard RUC
process. (The IWPUT is derived from components of the ``building-
block'' approach, described above, and is used as a measure of service
intensity.) Although CMS recognizes that the work values of codes may
change over time, it is the responsibility of the specialty society to
present compelling evidence that a code is misvalued.
We have some concerns that many of the codes that were reviewed in
the second 5-Year Review have been brought back again for further
consideration. The main purpose of the 5-Year Review is to identify
those services that need to be revalued because the work involved in
performing the service has changed. Since there have been three
opportunities for specialties to have services that are believed to be
undervalued reviewed, we expect that, for the most part, only those
services where there is compelling evidence of a change in the work
will be considered for further review. However, because there has been
little incentive for specialties to bring codes that may be overvalued
for review, such services will still need to be identified for the next
5-Year Review.
Table 1, Five-Year Review of Work Relative Value Units, lists the
codes reviewed during the 5-Year Review. This table includes the
following information:
CPT/HCPCS Code. This is the CPT or alphanumeric HCPCS code
for a service.
Modifier. A modifier -26 is shown if the work RVUs
represent the professional component of the service.
Description. This is an abbreviated version of the
narrative description of the code.
2005 Work RVU. The work RVUs that appeared in the CY 2005
Physician Fee Schedule final rule with comment period are shown for
each reviewed code.
Requested Work RVU. This column identifies the work RVUs
requested by the commenting specialty society or individual commenter.
If we received more than one comment on a code, the code is listed more
than once with the recommended RVUs. If the commenters did not
recommend specific RVUs, we indicate this by ``N/A''. A ``WD''
(withdrawal) indicates that the commenter withdrew the request for
review of a code and chose not to pursue review of the code under the
5-Year Review and that no RUC recommendation was received.
RUC Recommendation. This column identifies the work RVUs
recommended by the RUC. ``CPT'' indicates that the RUC referred this
code to the AMA CPT Editorial Panel for review and clarification and
recommended maintaining the current work RVUs. An ``(a)'' indicates the
commenting specialty society withdrew the proposal, and therefore, the
RUC recommends maintaining the current work RVUs. A ``(b)'' in this
column indicates there was no RUC recommendation.
HCPAC Recommendation. This column identifies the work RVUs
recommended by the HCPAC. An ``(a)'' indicates that the commenting
specialty society withdrew the proposal; therefore, the HCPAC
recommends maintaining the current work RVUs. A ``(b)'' in this column
indicates there was no HCPAC recommendation.
CMS Proposal. This column indicates whether we agreed with
the RUC recommendation (``Agree''); we are instead proposing to
maintain the present work RVUs (``Disagree''); we are proposing work
RVUs higher than the RUC recommendation (``Disagree/+''); or we are
proposing work RVUs that are less than the RUC recommendation
(``Disagree/-''). Codes for which we did not accept the RUC
recommendation are discussed in greater detail following Table 1. A
``(c)'' in this column indicates that in the absence of a RUC/HCPAC
recommendation we are proposing to maintain the present work RVUs.
Proposed base work RVU. This column contains the 2007
proposed work RVUs. The proposed work RVUs for surgical services with a
10- or 90-day global period do not include the application of the RUC-
recommended work values for E/M services. However, the additional work
value attributed to the increase for E/M services included as part of
the global period is reflected in the work RVUs contained in Addenda B
and C of this proposed rule. (Note: ** denotes codes that were deleted
for 2006.)
The following is a summary of our response to the RUC-recommended
work RVUs for the 5-Year Review of work. We sent the RUC approximately
709 codes to review. The RUC referred 136 codes to the CPT Editorial
Panel for review and 151 codes were withdrawn by the specialty
societies. We accepted the RUC's recommended work RVUs for 299 of the
services reviewed and disagreed with the RUC's recommended work RVUs
for 123 of the services reviewed. Of the 123 services for which we did
not accept the RUC's recommended work RVUs, we increased the work RVUs
for 3 services, recommended maintaining the current work RVUs for 48
services, and decreased the work RVUs for 72 services. (Note: 12 CPT
codes for nursing facility and rest home services that were referred to
the AMA CPT Editorial Panel were deleted for 2007.)
Additionally, the HCPAC reviewed a total of 7 services as part of
the 5-Year Review. Of the 7 services reviewed by the HCPAC, we accepted
the HCPAC recommendations for 1 service, recommended maintaining the
current work RVU for 1 service, decreased the work RVUs for 4 services,
and 1 code was withdrawn by the specialty society.
BILLING CODE 4120-01-P
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B. Discussion of Comments by Clinical Area
1. Dermatology and Plastic Surgery
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS-DERMATOLOGY AND PLASTIC SURGERY''
at the beginning of your comments.]
a. Hidradenitis
The American Society of Plastic Surgeons (ASPS) submitted the
hidradenitis services (CPT codes 11450, 11451, 11462, 11463, 11470 and
11471) as undervalued but, based on the very low response rate to the
survey they conducted the ASPS withdrew these codes from the 5-Year
Review.
b. Craniofacial Surgery
The ASPS originally requested that 10 craniofacial reconstruction
and fracture codes be reviewed. ASPS conducted a standard RUC survey
for these services and, based on the low survey response rate, withdrew
the following six CPT codes from the 5-Year Review: 21365, 21366,
21432, 21435, 21436, and 21470. ASPS presented survey data for the
remaining four CPT codes listed in Table 2 to the RUC indicating there
is compelling evidence that these codes had been valued based on an
incorrect assumption regarding the value of the bone graft portion of
each service.
Table 2
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
21145.............................. Reconstruction midface, LeFort I;
single piece, segment movement in
any direction, requiring bone
grafts (includes obtaining
autografts).
21146.............................. Reconstruction midface, LeFort I;
two pieces, segment movement in
any direction, requiring bone
grafts (includes obtaining
autografts) (e.g., ungrafted
unilateral alveolar cleft).
21147.............................. Reconstruction midface, LeFort I;
three or more pieces, segment
movement in any direction,
requiring bone grafts (includes
obtaining autografts) (e.g.,
ungrafted bilateral alveolar cleft
or multiple osteotomies).
21395.............................. Open treatment of orbital floor
blowout fracture; periorbital
approach with bone graft (includes
obtaining graft).
------------------------------------------------------------------------
RUC Recommendations
The RUC agreed that the appropriate increment of work for the bone
graft should be 50 percent of CPT code 20902, Bone graft, any donor
area; major or large (7.54 work RVUs x 50 percent = 3.77 work RVUs).
The RUC recommended that this increment of 3.77 be used and added to
the base code for each of these services.
The RUC-recommended work RVUs for these CPT codes are as follows:
21145 = 21.84 work RVUs; 21146 = 22.55 work RVUs, 21147 = 23.32 work
RVUs; and 21395 = 13.88 work RVUs.
CMS Proposed Valuation
We agree with the RUC recommendations for craniofacial surgery
services.
c. Other Plastic Surgery Services
ASPS initially submitted five additional services for review (see
Table 3). However, the specialty society was unable to obtain an
adequate survey response rate for these codes and withdrew them from
the RUC review. In addition, the RUC recommended that CPT code 15831
should be referred to the CPT Editorial Panel for review to capture the
new population of patients using this service.
Table 3
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
11960.............................. Insertion of tissue expander(s) for
other than breast, including
subsequent expansion.
15831.............................. Excision, excessive skin and
subcutaneous tissue (including
lipectomy); abdomen
(abdominoplasty).
19361.............................. Breast reconstruction with
latissimus dorsi flap, with or
without prosthetic implant.
43496.............................. Free jejunum transfer with
microvascular anastomosis.
49906.............................. Free omental flap with
microvascular anastomosis.
------------------------------------------------------------------------
We submitted four plastic surgery services for the 5-Year Review as
services that had never been reviewed by the RUC (see Table 4). In
addition, CPT code 15732 was submitted as it had been valued as an
inpatient service and it is now performed as an outpatient service.
Table 4
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
15100.............................. Split-thickness autograft, trunk,
arms, legs; first 100 sq cm or
less, or one percent of body area
of infants and children (except
15050).
15240.............................. Full thickness graft, free,
including direct closure of donor
site, forehead, cheeks, chin,
mouth, neck, axillae, genitalia,
hands, and/or feet; 20 sq cm or
less.
15732.............................. Muscle, myocutaneous, or
fasciocutaneous flap; head and
neck (e.g., temporalis, masseter
muscle, sternocleidomastoid,
levator scapulae).
15734.............................. Muscle, myocutaneous, or
fasciocutaneous flap; trunk.
------------------------------------------------------------------------
[[Page 37190]]
RUC Recommendations
The RUC was convinced that the survey data validated the current
valuation of CPT codes 15100, 15240, and 15734. The RUC recommended
that the current work RVUs be maintained for these CPT codes as
follows: 15100 = 9.04 work RVUs; 15240 = 9.03 work RVUs; and 15734 =
17.76 work RVUs. The RUC reviewed and discussed the issue concerning
the change in setting from inpatient to outpatient for CPT code 15732
and determined that this code describes two disparate procedures;
therefore, the RUC recommended that this CPT code be forwarded to the
CPT Editorial Panel for review.
CMS Proposed Valuation
We agree with the RUC recommendations for these plastic surgery
services.
d. Other Dermatology Services
The American Academy of Dermatology (AAD) and a pharmaceutical
company submitted CPT code 96567, Photodynamic therapy by external
application of light to destroy premalignant and/or malignant lesions
of the skin and adjacent mucosa (e.g., lip) by activation of
photosensitive drug(s), each phototherapy exposure session, for the 5-
Year Review but, subsequent to discussions with the RUC regarding the
need for potential CPT revisions, withdrew the code from the 5-Year
Review.
We submitted the CPT codes for integumentary services in Table 5
for review because they had never been previously reviewed by the RUC.
Table 5
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
11100.............................. Biopsy of skin, subcutaneous tissue
and/or mucous membrane (including
simple closure), unless otherwise
listed; single lesion.
12052.............................. Layer closure of wounds of face,
ears, eyelids, nose, lips and/or
mucous membranes; 2.6 cm to 5.0
cm.
13121.............................. Repair, complex, scalp, arms, and/
or legs; 2.6 cm to 7.5 cm.
14040.............................. Adjacent tissue transfer or
rearrangement, forehead, cheeks,
chin, mouth, neck, axillae,
genitalia, hands and/or feet;
defect 10 sq cm or less.
14060.............................. Adjacent tissue transfer or
rearrangement, eyelids, nose, ears
and/or lips; defect 10 sq cm or
less.
17003.............................. Destruction (e.g., laser surgery,
electrosurgery, cryosurgery,
chemosurgery, surgical
curettement), all benign or
premalignant lesions (e.g.,
actinic keratoses) other than skin
tags or cutaneous vascular
proliferative lesions; second
through 14 lesions, each (List
separately in addition to code for
first lesion).
17262.............................. Destruction, malignant lesion
(e.g., laser surgery,
electrosurgery, cryosurgery,
chemosurgery, surgical
curettement), trunk, arms or legs;
lesion diameter 1.1 to 2.0 cm.
17281.............................. Destruction, malignant lesion
(e.g., laser surgery,
electrosurgery, cryosurgery,
chemosurgery, surgical
curettement), face, ears, eyelids,
nose, lips, mucous membrane;
lesion diameter 0.6 to 1.0 cm.
------------------------------------------------------------------------
We requested that CPT code 17003 be reviewed because we believe
that advances in technology have likely resulted in a modification to
the physician work required to accomplish the procedure. In discussions
at the RUC meeting, we noted that new Medicare coverage policies
related to actinic keratoses (AK) have increased the reporting of this
service to describe cryosurgical destruction of AK. Standard RUC
surveys were conducted for all of these services.
RUC Recommendations
Based on a review of the survey data, the RUC was convinced that
the survey data validated the current valuation of the following
services and recommended the work RVUs for these CPT codes be
maintained as follows: 11100 = 0.81 work RVUs; 12052 = 2.77 work RVUs;
13121 = 4.32 work RVUs; 14040 = 7.86 work RVUs; 14060 = 8.49 work RVUs;
17262 = 1.58 work RVUs; and 17281 = 1.72 work RVUs.
For CPT code 17003, the RUC reviewed previous and current survey
data and agreed that the application of cryosurgery to each lesion
requires no more than two minutes of physician time. Therefore, the RUC
recommended a work RVU of 0.07 for CPT code 17003. The RUC determined
that the revision to the work RVUs for CPT code 17003 created a rank
order anomaly in this family of codes. In addition to referring codes
in this family to the CPT Editorial Panel to clarify the code
descriptors, the RUC in February 2006 also recommended a change to the
work RVUs for CPT code 17004, Destruction (e.g., laser surgery,
electrosurgery, cryosurgery, chemosurgery, surgical curettement), all
benign or premalignant lesions (e.g., actinic keratoses) other than
skin tags or cutaneous vascular proliferative lesions; 15 or more
lesions. This was based on the understanding that when rank order
anomalies were identified, the specialty could bring these additional
codes forward for consideration for re-evaluation under the 5-Year
Review at the next RUC meeting (that is, February 2006).
A standard RUC survey was conducted for this code and based on the
survey responses, the specialty society recommended a change in the
intra-service work descriptions to reflect a greater time based on
their belief that the destruction of premalignant lesions requires more
time than benign lesions. Thus, the intra-service period for CPT code
17004 was changed to 20 minutes which is twice as much as the time
associated with the destruction of benign lesion in CPT code 17111,
Destruction (e.g., laser surgery, electrosurgery, cryosurgery,
chemosurgery, surgical curettement), of flat warts, molluscum
contagiosum, or milia; 15 or more lesions, of 10 minutes. The RUC
agreed to this time change and recommended work RVUs of 1.80 for CPT
code 17004.
CMS Proposed Valuation
We are in agreement with the RUC-recommended work RVUs for these
services with the exception of CPT code 17004. For CPT code 17004, we
believe that the work associated with benign and premalignant lesions
is comparable and, therefore, the work RVUs for CPT code 17004 should
be more similar to that of CPT code 17111, which is 0.92. Based on our
proposed valuation of 17003 (the code used for 2-14 lesions), of 0.07
work RVUs, the 14th lesion would equal 0.91 work RVUs (0.07 x 13
lesions) plus 0.6 work RVUs for the initial lesion, that is, base code
CPT code 17000, which is billed once in conjunction with 17003. We are
proposing to value CPT code 17004, for 15 or more lesions, at 1.58 work
RVUs by adding the 0.07 work RVU increment of 17003 and the 0.6 work
RVUs for the base code, CPT code 17000, which is not billed in
conjunction with CPT code 17004.
[[Page 37191]]
e. Mohs Surgery
We referred the Mohs surgery codes for review because this family
of services has never been surveyed and reviewed by the RUC (see Table
6).
Table 6
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
17304.............................. Chemosurgery (Mohs micrographic
technique), including removal of
all gross tumor, surgical excision
of tissue specimens, mapping,
color coding of specimens,
microscopic examination of
specimens by the surgeon, and
complete histopathologic
preparation including the first
routine stain (e.g., hematoxylin
and eosin, toluidine blue); first
stage, fresh tissue technique, up
to 5 specimens.
17305.............................. Chemosurgery (Mohs micrographic
technique), including removal of
all gross tumor, surgical excision
of tissue specimens, mapping,
color coding of specimens,
microscopic examination of
specimens by the surgeon, and
complete histopathologic
preparation including the first
routine stain (e.g., hematoxylin
and eosin, toluidine blue); second
stage, fixed or fresh tissue, up
to 5 specimens).
------------------------------------------------------------------------
The specialty society conducted surveys to collect data for these
two codes. The workgroup then reviewed the history of these services,
including the fact that the nomenclature for these services is not
consistent with other integumentary coding conventions in CPT and that
the RUC had previously indicated that the specialty society should work
with the CPT Editorial Panel to redefine these services.
RUC Recommendations
The RUC recommended that these CPT codes be referred to the CPT
Editorial Panel.
CMS Proposed Valuation
We will maintain the current valuation for these services pending
the results of the review of the CPT Editorial Panel.
f. Excision of Lesions
We submitted all of the excision of lesion codes for review, noting
that these services should be surveyed and reviewed by the RUC (see
Table 7--benign: CPT codes 11400 through 11446, and malignant: CPT
codes 11600 through 11646).
The work RVUs for the codes predominantly performed by the surgical
specialties (CPT codes representing services to excise larger lesions)
were all valued, with the exception of two CPT codes, by acceptable RUC
surveys. However, there were no acceptable RUC surveys for the 18
services predominantly performed by the dermatologists (CPT codes
representing services to excise smaller lesions) due to incomplete
surveys and low response rates.
RUC Recommendations
The RUC agreed that the primary difference in the work between the
family of codes for excision of benign lesions versus those codes for
excision of malignant lesions (see Table 7) is in the pre-evaluation
time (that is, additional planning, and discussions with the patient),
the intensity of the intra-service time, and the level of post-
operative visit.
The workgroup used the RUC surveys to determine the work RVUs for
those services performed by the surgeons and then applied the building-
block approach using the IWPUT values of the codes primarily performed
by the surgical specialties to derive IWPUT values and corresponding
work RVUs for the CPT codes primarily performed by dermatology. (The
IWPUT is derived by dividing the intra-service work by the intra-
service time, and is used to measure the relative intensity of the work
between services.)
As a result of the application of the building-block methodology to
the codes without RUC acceptable surveys, the RUC recommended that 24
codes retain their current work RVUs, 5 codes have decreased work RVUs,
and 7 codes have increased work RVUs. The specific RUC recommendations
for these CPT codes are presented in Table 7.
[[Page 37192]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.035
[[Page 37193]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.036
[[Page 37194]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.037
[[Page 37195]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.038
BILLING CODE 4120-01-C
CMS Proposed Valuation
We are in agreement with the RUC recommendations for the excision
of lesions services.
2. Orthopedic Surgery
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS--ORTHOPEDIC SURGERY'' at the
beginning of your comments.]
a. Tumor Procedures
The American Academy of Orthopaedic Surgeons (AAOS) submitted CPT
codes in the following three families of tumor procedures for review.
(See Table 8, Table 9, and Table 10.)
Table 8.--Family 1--Excision of Deep Soft Tissue Mass
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
21556.............................. Excision tumor, soft tissue of neck
or thorax; deep, subfascial,
intramuscular
23076.............................. Excision, soft tissue tumor,
shoulder area; deep, subfascial,
or intramuscular.
24076.............................. Excision, tumor, soft tissue of
upper arm or elbow area; deep
(subfascial or intramuscular).
25076.............................. Excision, tumor, soft tissue of
forearm and/or wrist area; deep
(subfascial or intramuscular).
27048.............................. Excision, tumor, pelvis and hip
area; deep, subfascial,
intramuscular.
27328.............................. Excision, tumor, thigh or knee
area, deep, subfascial, or
intramuscular.
27619.............................. Excision, tumor, leg or ankle area;
deep (subfascial or
intramuscular).
28045.............................. Excision, tumor, foot; deep,
subfascial, intramuscular.
------------------------------------------------------------------------
Table 9.--Family 2--Radical Resection of Soft Tissue Sarcoma
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
24077.............................. Radical resection of tumor (e.g.,
malignant neoplasm), soft tissue
of upper arm or elbow area.
25077.............................. Radical resection of tumor (e.g.,
malignant neoplasm), soft tissue
of forearm and/or wrist area.
27049.............................. Radical resection of tumor, soft
tissue of pelvis and hip area
(e.g., malignant neoplasm).
27329.............................. Radical resection of tumor (e.g.,
malignant neoplasm), soft tissue
of thigh or knee area.
27615.............................. Radical resection of tumor (e.g.,
malignant neoplasm), soft tissue
of leg or ankle area).
------------------------------------------------------------------------
Table 10.--Family 3--Radical Resection of Bone Sarcoma
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
21935.............................. Radical resection of tumor (e.g.,
malignant neoplasm), soft tissue
of back or flank.
23200.............................. Radical resection for tumor;
clavicle.
23210.............................. Radical resection for tumor;
scapula.
23220.............................. Radical resection of bone tumor,
proximal humerus.
24150.............................. Radical resection for tumor, shaft
or distal humerus.
24151.............................. Radical resection for tumor, shaft
or distal humerus; with autograft
(includes obtaining graft).
[[Page 37196]]
24152.............................. Radical resection for tumor, radial
head or neck.
24153.............................. Radical resection for tumor, radial
head or neck; with autograft
(includes obtaining graft).
25170.............................. Radical resection for tumor, radius
or ulna.
27076.............................. Radical resection of tumor or
infection; ilium, including
acetabulum, both pubic rami, or
ischium and acetabulum.
27078.............................. Radical resection of tumor or
infection; ischial tuberosity and
greater trochanter of femur.
27365.............................. Radical resection of tumor, bone,
femur or knee.
27645.............................. Radical resection of tumor, bone;
tibia.
27646.............................. Radical resection of tumor, bone;
fibula.
27647.............................. Radical resection of tumor; talus
or calcaneus.
------------------------------------------------------------------------
The specialty subsequently withdrew CPT codes 21935, 24151, and
24153 from the 5-Year Review. A minisurvey methodology was used for all
three families of codes.
RUC Recommendations
Based on a review of the survey results for the codes in Families 1
and 2, the RUC recommended referring these codes to the CPT Editorial
Panel for clarification. The RUC indicated that the survey data from
the specialty society described a hospitalized patient as the typical
patient. However, our data indicates that the typical patient is not
hospitalized and that this inconsistency could be the result of
ambiguous CPT descriptors.
For the services in Family 3, the RUC discussion focused on the
issue of whether there may also be different patient populations
covered by each of these codes.
The RUC also recommended referring the codes in Family 3 to the CPT
Editorial Panel for clarification.
CMS Proposed Valuation
We will maintain the current valuation for these services pending
the results of the review by the CPT Editorial Panel.
b. Trauma Procedures
The AAOS submitted the following trauma procedure codes for review
(see Table 11). Standard RUC surveys of these services were conducted.
Table 11
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
20680.............................. Removal of implant; deep (e.g.,
buried wire, pin, screw, metal
band, nail, rod or plate).
20692.............................. Application of a multiplane (pins
or wires in more than one plane),
unilateral, external fixation
system (e.g., Ilizarov, Monticelli
type).
24430.............................. Repair of nonunion or malunion,
humerus; without graft (e.g.,
compression technique).
27465.............................. Osteoplasty, femur; shortening
(excluding 64876).
27470.............................. Repair, nonunion or malunion,
femur, distal to head and neck;
without graft (e.g., compression
technique).
27472.............................. Repair, nonunion or malunion,
femur, distal to head and neck;
with iliac or other autogeneous
bone graft (includes obtaining
graft).
27709.............................. Osteotomy; tibia and fibula.
27720.............................. Repair of nonunion or malunion,
tibia; without graft, (e.g.,
compression technique).
------------------------------------------------------------------------
RUC Recommendations
Based on a review of the compelling evidence, the RUC made the
following recommendations.
For CPT code 20680, the RUC agreed that the intra-operative time
for this code is misvalued based on the significant changes in
physician work for the removal of deep implants due to changes in
technology. Using the survey's 25th percentile value for the work RVUs
along with the 25th percentile value for intra-service time, and
adjusting for the fact that this procedure is typically performed in an
outpatient setting, the RUC recommended a work RVU of 5.86 for this
service.
For CPT code 24430, the workgroup did not believe that the current
work value for CPT code 24430 accounts for all the work typically
involved with this service. This is based on the survey's physician
time and visit data and a comparison to CPT code 24515, Open treatment
of humeral shaft fracture with plate/screws, with or without cerclage,
which is a less complex procedure than CPT code 24430. The RUC
recommended a work RVU of 14.00 and an intra-service time of 102
minutes for this service, which was the 25th percentile for work of the
survey data.
Based on a comparison to CPT code 27506, Open treatment of femoral
shaft fracture, with or without external fixation, with insertion of
intramedullary implant, with or without and/or locking screws, the
workgroup determined that the current work RVUs for CPT code 27465, do
not fully account for the work typically involved in shortening the
femur because it typically includes the insertion of an intermedullary
nail. However, the workgroup believed that CPT code 27465 should be
valued lower than the reference service code, CPT code 27454,
Osteotomy, multiple, with realignment on intramedullary rod, femoral
shaft (e.g., Sofield type procedure), which has a work RVU of 17.53,
and is a greater intensity procedure. The RUC-recommended work RVU for
CPT code 27645 was 17.50, based on the median of the survey data.
Based on a review of the survey data, the workgroup did not believe
that there was compelling evidence to change the work RVU for CPT code
27470. Therefore, the RUC recommended that the current work RVU of
16.05 be maintained for this service. However, the workgroup also
recommended using the new survey times as they believed the Harvard
times from the original Harvard relative value study, which was used to
establish RVUs at the outset of the Medicare PFS, are inflated.
For CPT code 27709, Osteotomy; tibia and fibula, the RUC reviewed
the survey time and compared this service to CPT
[[Page 37197]]
code 27705, Osteomy, tibia, which has a work RVU of 10.36. The RUC
recommended a work RVU of 16.50 for CPT code 27709 which would place
the code in proper rank order with CPT code 27705.
The RUC recommended the referral of CPT codes 20692, 27472, and
27720 to the CPT Editorial Panel to clarify whether these 90-day global
period codes should be exempt from modifier 51. (Modifier 51 denotes
that a multiple procedure was performed.) The RUC was concerned that
attempting to value these codes would lead to double counting some of
the work.
The RUC-recommended valuation for these CPT codes was as follows:
20680 = 5.86 work RVUs; 24430 = 14.00 work RVUs; 27465 = 17.50 work
RVUs; 27470 = 16.05 work RVUs; and 27709 = 16.50 work RVUs.
CMS Proposed Valuation
We are in agreement with the RUC-recommended work values for these
trauma services.
c. Total Elbow and General Procedures
AAOS submitted the following elbow athroplasty service for review
(see Table 12).
Table 12
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
24363.............................. Arthroplasty, elbow; with distal
humerus and proximal ulnar
prosthetic replacement (e.g.,
total elbow).
------------------------------------------------------------------------
In addition, we submitted the following CPT codes, in Table 13, for
review.
Table 13
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
20600.............................. Arthrocentesis, aspiration and/or
injection; small joint or bursa
(e.g., fingers, toes).
20610.............................. Arthrocentesis, aspiration and/or
injection; major joint or bursa
(e.g., shoulder, hip, knee joint,
subacromial bursa).
29075.............................. Application, cast; elbow to finger
(short arm).
------------------------------------------------------------------------
Standard RUC surveys of these services were conducted.
RUC Recommendations
The RUC recommended maintaining the current work RVUs for CPT codes
20600, 20610, and 29075 because of the low response rate for the
surveys and the lack of compelling evidence for changing the work
value.
Based on a review of the survey data and information provided by
the presenting specialty societies, AAOS and the American Society of
Shoulder and Elbow Surgeons, the RUC concluded that the CPT code 24363
should be valued the same as CPT code 23472, Arthroplasty, glenohumeral
joint; total shoulder (glenoid and proximal humeral replacement (e.g.,
total shoulder), and recommended a work RVU of 21.07 to maintain
appropriate rank-order alignment with this family of codes. The RUC-
recommended valuation for these CPT codes was as follows: 20600 = 0.66
work RVUs; 20610 = 0.79 work RVUs; 24363 = 21.07 work RVUs; and 29075 =
0.77 work RVUs.
CMS Proposed Valuation
We agree with the RUC-recommended work RVUs for these elbow and
general procedure services.
d. Wrist, Hand and Finger
We submitted the CPT codes in Table 14 for review.
Table 14
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
25447.............................. Arthroplasty, interposition,
intercarpal or carpometacarpal
joints.
26055.............................. Tendon sheath incision (e.g., for
trigger finger).
26160.............................. Excision of lesion of tendon sheath
or joint capsule (e.g., cyst,
mucous cyst, or ganglion), hand or
finger.
26600.............................. Closed treatment of metacarpal
fracture, single; without
manipulation, each bone.
26951.............................. Amputation, finger or thumb,
primary or secondary, any joint or
phalanx, single, including
neurectomies; with direct closure.
64721.............................. Neuroplasty and/or transposition;
median nerve at carpal tunnel.
------------------------------------------------------------------------
CPT code 64702, Neuroplasty; digital, one or both, same digit, was
submitted by the American Society for Surgery of the Hand (ASSH) with
the rationale that this code is based on inaccurate Harvard physician
times that are low compared to other hand surgery codes. Standard RUC
surveys of these services were conducted.
RUC Recommendations
Based on a review of the survey data, the RUC recommended that the
current work RVUs be maintained for CPT codes 25447, 26055, 26160, and
64721.
For CPT code 26600, the workgroup examined the survey data
presented by the specialty society and agreed that the current work
value of 1.96 RVUs may not fully reflect the value of all post-
operative visits that are the current standard of care and that the CPT
code most frequently cited as a reference code (CPT code 26720, Closed
treatment of phalangeal shaft fracture, proximal or middle phalanx,
finger or thumb; without manipulation, each), also understates the
number of post-operative visits. The workgroup validated the survey
median value of 2.40 work RVUs by performing a
[[Page 37198]]
building-block calculation that added the value of an additional post-
operative visit (CPT code 99212 at 0.43 work RVUs) to the current work
value for CPT code 26600 of 1.96 for a total of 2.39 work RVUs. Since
this value was almost identical to the median survey value of 2.40, the
RUC recommended accepting this median value for the work RVUs for CPT
code 26600.
For CPT code 26951, the RUC workgroup agreed that the current value
of 4.58 work RVUs for this code creates a rank order anomaly when
compared to the reference code (CPT code 26185, Sesamoidectomy, thumb
or finger (separate procedure)), which has a work RVU of 5.24. Based on
a review of survey data, the RUC recommended that CPT code 26951 should
be assigned work RVUs of 5.25 (the 25th percentile survey value) but
that the survey median intra-service time of 45 minutes should be used
since that is equal to the reference code.
For CPT code 64702, the RUC workgroup agreed that the current value
for this service of 4.22 work RVUs does not include the number of post-
operative days typically associated with this procedure. The workgroup
believed that adding the work RVUs (1.3 work RVUs) associated with two
additional outpatient visits, represented by CPT code 99213, produces
an appropriate work RVU for this service and also places CPT code 64702
in the proper rank order with the reference service. The RUC
recommended 5.52 work RVUs for CPT code 64702.
The RUC-recommended work RVUs for these CPT codes are as follows:
25447 = 10.35 work RVUs; 26055 = 2.69 work RVUs; 26160 = 3.15 work
RVUs; 26600 = 2.40 work RVUs; 26951 = 5.25 work RVUs; 64702 = 5.52 work
RVUs; and 64721 = 4.28 work RVUs.
CMS Proposed Valuation
We are in agreement with the RUC-recommended work values for wrist,
hand and finger services.
e. Total Joint and Hip Fracture
We submitted three CPT codes for review (see Table 15).
Table 15
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
27130.............................. Arthroplasty, acetabular and
proximal femoral prosthetic
replacement (total hip
arthroplasty), with or without
autograft or allograft.
27236.............................. Open treatment of femoral fracture,
proximal end, neck, internal
fixation or prosthetic
replacement.
27447.............................. Arthroplasty, knee, condyle and
plateau; medial AND lateral
compartments with or without
patella resurfacing (total knee
arthroplasty).
------------------------------------------------------------------------
The specialty society did not submit surveys for these codes, which
is the accepted RUC method, for the RUC's consideration of changes to
current work RVUs. Instead the specialty society developed proposed
values for these services based on data obtained from the VA NSQIP
database and the Medicare DRG database. The specialty society did
survey its membership to obtain the data, but did not provide the
workgroup or the RUC with this information, stating the vignettes did
not describe a typical patient for this series of codes. Thus, the
survey data for these codes was not available for the RUC workgroup to
review at its August 2005 meeting.
The RUC requested that the specialty society survey its members on
these three codes so that survey data could be used to evaluate the
codes at the September 2005 RUC meeting. The specialty society used
survey data, as well as NSQIP data and Medicare DRG data, to evaluate
pre-service and intra-service times for these codes. The workgroup, as
well as the RUC, was uncomfortable with mixing data from three separate
sources in lieu of the established and accepted methodology of the RUC.
The specialty society maintained the NSQIP data was more accurate than
the survey data.
RUC Recommendations
The RUC did not find any compelling evidence to change the current
work RVUs assigned to these services. Based on a review of the data,
the RUC recommended maintaining the current work RVUs of 20.09 for CPT
code 27130, 15.58 for CPT code 27236 and 21.45 for CPT code 27447, but
also recommended using the new physician time data for each of these
services.
CMS Proposed Valuation
For these three CPT codes (27130, 27236,and 27447), the specialty
society used NSQIP and Medicare DRG data instead of the standard RUC
survey methodology to create an intra-service time. Medicare DRG data
has not been used by CMS or the RUC to evaluate new or existing CPT
codes. CPT code 27130 has never been reviewed by the RUC. It currently
has 20.09 work RVUs which is based on the following Harvard time data:
pre-service time of 68 minutes, intra-service time of 128 minutes,
post-service time of 36 minutes and eight hospital days. We believe
that this service can be compared to CPT codes 43641, Vagotomy
including pyloroplasty, with or without gastrostomy; parietal cell
(highly selective), and 60260, Thyroidectomy, removal of all remaining
thyroid tissue following previous removal of a portion of thyroid. Both
codes were reviewed by the RUC during the second 5-Year Review. CPT
code 43641 has 60 minutes pre-service time, 150 minutes intra-service
time, 30 minutes post-service time, and 6 hospital days, resulting in
work RVUs of 17.24. CPT code 60260 has 60 minutes pre-service time, 145
minutes intra-service time and 30 minutes post-service time with 2
hospital days, resulting in work RVUs of 17.44. We believe CPT code
27130 is similar in work and intensity to CPT code 43641, and if one
removes 2 hospital days (code 99231), this would result in a work RVU
of 15.96. Therefore, we recommend a work RVU of 15.96 for CPT code
27130.
CPT code 27236 has never been reviewed by the RUC. It has a pre-
service time of 74 minutes, an intra-service time of 89 minutes, a
post-service time of 27 minutes, 100 minutes for hospital days, and 57
minutes for office visits for a total time of 347 minutes based on the
Harvard time data, resulting in work RVUs of 15.58. We believe CPT
codes 34421, Thrombectomy, direct or with catheter; vena cava, iliac,
femoropopliteal vein, by leg incision, and 47600, Cholecystectomy,
which were included in the second 5-Year Review, are similar in work
intensity and time to CPT code 27236. CPT code 34421 has a pre-service
time of 70 minutes, an intra-service time of 95 minutes, a post-service
time of 221 minutes, and total time of 386 minutes, resulting in work
RVUs of 11.98. CPT code 47600 has a pre-service time of 75 minutes, an
intra-service time of 80 minutes, and a post-service time of 194
minutes for a total time of 349 minutes, resulting in work
[[Page 37199]]
RVUs of 13.56. We propose a work RVU of 12.77 for CPT code 27236, which
is the median value for these two codes and maintains relativity within
this family of codes.
CPT Code 27447 has never been reviewed by the RUC. It has 21.45
work RVUs, which is based on the following Harvard time data: pre-
service time of 60 minutes, intra-service time 139 minutes, post-
service time of 37 minutes, 118 minutes for hospital days, and 54
minutes for office visits for a total time of 408 minutes. We believe
this service is comparable to CPT code 35671, Bypass graft, with other
than vein; popliteal-tibial or -peroneal artery, which was reviewed
during the second 5-Year Review. This service has a pre-service time of
70 minutes, an intra-service time of 135 minutes, and a post-service
time of 206 minutes for a total time of 411 minutes, resulting in work
RVUs of 19.30. We believe CPT code 27447 is similar in work intensity
and time to CPT code 35671 and propose work RVUs of 19.30 for CPT code
27447.
f. Additional Fracture Codes
The AAOS also submitted the following CPT codes listed in Table 16
and the ASSH submitted CPT code 25620. However, the specialty societies
believed clarification was needed for the CPT descriptor for these
services, as there was a question whether the current valuation for
these codes includes the application of internal and external fixation
to a fracture site.
Table 16
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
23515.............................. Open treatment of clavicle
fracture, with or without internal
or external fixation.
23585.............................. Open treatment of scapular fracture
(body, glenoid or acromion) with
or without internal fixation.
23615.............................. Open treatment of proximal humeral
(surgical or anatomical neck)
fracture, with or without internal
or external fixation, with or
without repair of tuberosity(s).
23616.............................. Open treatment of proximal humeral
(surgical or anatomical neck)
fracture, with or without internal
or external fixation, with or
without repair of tuberosity(s);
with proximal humeral prosthetic
replacement.
23630.............................. Open treatment of greater humeral
tuberosity fracture, with or
without internal or external
fixation.
23670.............................. Open treatment of shoulder
dislocation, with fracture of
greater humeral tuberosity, with
or without internal or external
fixation.
23680.............................. Open treatment of shoulder
dislocation, with surgical or
anatomical neck fracture, with or
without internal or external
fixation.
24545.............................. Open treatment of humeral
supracondylar or transcondylar
fracture, with or without internal
or external fixation; without
intercondylar extension.
24546.............................. Open treatment of humeral
supracondylar or transcondylar
fracture, with or without internal
or external fixation; with
intercondylar extension.
24575.............................. Open treatment of humeral
epicondylar fracture, medial of
lateral, with or without internal
or external fixation.
24579.............................. Open treatment of humeral condylar
fracture, medial or lateral, with
or without internal or external
fixation.
24635.............................. Open treatment of Monteggia type of
fracture dislocation at elbow
(fracture proximal end of ulna
with dislocation of radial head),
with or without internal or
external fixation.
24665.............................. Open treatment of radial head or
neck fracture, with or without
internal fixation or radial head
excision.
24685.............................. Open treatment of ulnar fracture
proximal end (olecranon process),
with or without internal or
external fixation.
25515.............................. Open treatment of radial shaft
fracture, with or without internal
or external fixation.
25526.............................. Open treatment of radial shaft
fracture, with internal and/or
external fixation and open
treatment, with or without
internal or external fixation of
distal radioulnar joint (Galeazzi
fracture/dislocation), includes
repair of triangular
fibrocartilage complex.
25545.............................. Open treatment of ulnar shaft
fracture, with or without internal
or external fixation.
25574.............................. Open treatment of radial AND ulnar
shaft fractures, with internal or
external fixation; of radius OR
ulna.
25575.............................. Open treatment of radial AND ulnar
shaft fractures, with internal or
external fixation; of radius AND
ulna.
25620.............................. Open treatment of distal radial
fracture (e.g., Colles or Smith
type) or epiphyseal separation,
with or without fracture of ulnar
styloid, with or without internal
or external fixation.
25628.............................. Open treatment of carpal scaphoid
(navicular) fracture, with or
without internal or external
fixation.
26615.............................. Open treatment of metacarpal
fracture, single, with or without
internal or external fixation,
each bone.
26665.............................. Open treatment of carpometacarpal
fracture dislocation, thumb
(Bennett fracture), with or
without internal or external
fixation.
26685.............................. Open treatment of carpometacarpal
dislocation, other than thumb,
with or without internal or
external fixation, each joint.
26715.............................. Open treatment of
metacarpophalangeal dislocation,
single, with or without internal
or external fixation.
26735.............................. Open treatment of phalangeal shaft
fracture, proximal or middle
phalanx, finger or thumb, with or
without internal or external
fixation, each.
26746.............................. Open treatment of articular
fracture, involving
metacarpophalangeal or
interphalangeal joint, with or
without internal or external
fixation, each.
26765.............................. Open treatment of distal phalangeal
fracture, finger or thumb, with or
without internal or external
fixation, each.
26785.............................. Open treatment of interphalangeal
joint dislocation, with or without
internal or external fixation,
single.
27248.............................. Open treatment of greater
trochanteric fracture, with or
without internal of external
fixation.
27511.............................. Open treatment of femoral
supracondylar or transcondylar
fracture without intercondylar
extension, with or without
internal or external fixation.
27513.............................. Open treatment of femoral
supracondylar or transcondylar
fracture with intercondylar
extension, with or without
internal or external fixation.
27514.............................. Open treatment of femoral fracture,
distal end, medial of lateral
condyle, with or without internal
or external fixation.
27519.............................. Open treatment of distal femoral
epiphyseal separation, with or
without internal or external
fixation.
27535.............................. Open treatment of tibial fracture,
proximal (plateau); unicondylar,
with or without internal of
external fixation.
27540.............................. Open treatment of intercondylar
spine(s) and/or tuberosity
fracture(s) of the knee, with or
without internal or external
fixation.
27556.............................. Open treatment of knee dislocation,
with or without internal or
external fixation; without primary
ligamentous repair of augmentation/
reconstruction.
27766.............................. Open treatment of medial malleolus
fracture, with or without internal
or external fixation.
27784.............................. Open treatment of proximal fibula
or shaft fracture, with or without
internal or external fixation.
[[Page 37200]]
27792.............................. Open treatment of distal fibular
fracture (lateral malleolus), with
or without internal or external
fixation.
27814.............................. Open treatment of bimalleolar ankle
fracture, with or without internal
or external fixation.
27822.............................. Open treatment of trimalleolar
ankle fracture, with or without
internal or external fixation,
medial and/or lateral malleolus;
without fixation of posterior lip.
27826.............................. Open treatment of fracture of
weight bearing articular surface/
portion of distal tibia (e.g.,
pilon or tibial plafond), with
internal or external fixation; of
fibula only.
27827.............................. Open treatment of fracture of
weight bearing articular surface/
portion of distal tibia (e.g.,
pilon or tibial plafond), with
internal or external fixation; of
tibia only.
27828.............................. Open treatment of fracture of
weight bearing articular surface/
portion of distal tibia (e.g.,
pilon or tibial plafond), with
internal or external fixation; of
both tibia and fibula.
27829.............................. Open treatment of distal
tibiofibular joint (syndesmosis)
disruption, with or without
internal or external fixation.
27832.............................. Open treatment of proximal
tibiofibular joint dislocation,
with or without internal or
external fixation, or with
excision of proximal fibula.
28415.............................. Open treatment of calcaneal
fracture, with or without internal
or external fixation.
28445.............................. Open treatment of talus fracture,
with or without internal or
external fixation.
28465.............................. Open treatment of tarsal bone
fracture (except talus and
calcaneus), with or without
internal or external fixation,
each.
28485.............................. Open treatment of metatarsal
fracture, with or without internal
or external fixation, each.
28505.............................. Open treatment of fracture of great
toe, phalanx or phalanges, with or
without internal or external
fixation.
28525.............................. Open treatment of fracture, phalanx
or phalanges, other than great
toe, with or without internal or
external fixation, each.
28555.............................. Open treatment of tarsal bone
dislocation, with or without
internal or external fixation.
28585.............................. Open treatment of talotarsal joint
dislocation, with or without
internal or external fixation.
28615.............................. Open treatment of tarsometatarsal
joint dislocation, with or without
internal or external fixation.
28645.............................. Open treatment of
metatarsophalangeal joint
dislocation, with or without
internal or external fixation.
28675.............................. Open treatment of interphalangeal
joint dislocation, with or without
internal or external fixation.
------------------------------------------------------------------------
RUC Recommendations
The RUC recommended that these CPT codes be referred to the CPT
Editorial Panel for review and clarification.
CMS Proposed Valuation
We will maintain the current valuation for these services pending
the results of the review by the CPT Editorial Panel.
3. Gynecology, Urology, Pain Medicine, and Neurosurgery
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS--GYNECOLOGY, UROLOGY, PAIN
MEDICINE, AND NEUROSURGERY'' at the beginning of your comments.]
a. Obstetrics and Gynecology
The American College of Obstetricians and Gynecologists (ACOG)
submitted the CPT codes in Table 17 for review.
Table 17
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
49200.............................. Excision or destruction, open,
intra-abdominal or retroperitoneal
tumors or cysts or endometriomas.
49201.............................. Excision or destruction, open,
intra-abdominal or retroperitoneal
tumors or cysts or endometriomas;
extensive.
56631.............................. Vulvectomy, radical, partial; with
unilateral inguinofemoral
lymphadenectomy.
56632.............................. Vulvectomy, radical, partial; with
bilateral inguinofemoral
lymphadenectomy.
56634.............................. Vulvectomy, radical, complete; with
unilateral inguinofemoral
lymphadenectomy.
56637.............................. Vulvectomy, radical, complete; with
bilateral inguinofemoral
lymphadenectomy.
56640.............................. Vulvectomy, radical, complete, with
inguinofemoral, iliac, and pelvic
lymphadenectomy.
57160.............................. Fitting and insertion of pessary or
other intravaginal support device.
57240.............................. Anterior colporrhaphy, repair of
cystocele with or without repair
of urethrocele.
57250.............................. Posterior colporrhaphy, repair of
rectocele with or without
perineorrhaphy.
57260.............................. Combined anteroposterior
colporrhaphy.
57265.............................. Combined anteroposterior
colporrhaphy; with enterocele
repair.
57550.............................. Excision of cervical stump, vaginal
approach.
57555.............................. Excision of cervical stump, vaginal
approach; with anterior and/or
posterior repair.
57556.............................. Excision of cervical stump, vaginal
approach; with repair of
enterocele.
------------------------------------------------------------------------
However, the specialty society subsequently withdrew the following
CPT codes: 49200, 49201, 56631, 56632, 56634, 56637, 56640, 57550,
57555, and 57556.
We identified five CPT codes for review but withdrew one code, CPT
code 58260 (see Table 18).
Table 18
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
57500.............................. Biopsy, single or multiple, or
local excision of lesion, with or
without fulguration (separate
procedure).
58120.............................. Dilation and curettage, diagnostic
and/or therapeutic
(nonobstetrical).
58150.............................. Total abdominal hysterectomy
(corpus and cervix), with or
without removal of tube(s), with
or without removal of ovary(s).
58260.............................. Vaginal hysterectomy, for uterus
250 grams or less.
[[Page 37201]]
58720.............................. Salpingo-oophorectomy, complete or
partial, unilateral or bilateral
(separate procedure).
------------------------------------------------------------------------
A standard RUC survey with over 30 responses was used for these
codes.
RUC Recommendations
The RUC recommended maintaining the existing RVUs for CPT codes
57160, 58120 and 58720. The RUC believed there was no compelling
evidence presented to indicate that there had been a change in work for
CPT code 57160. The RUC also agreed with the specialty society that the
survey data collected validated the existing times and existing RVUs
for CPT codes 58120 and 58720.
The RUC recommended increasing the work value for the remaining CPT
codes. The RUC agreed with the specialty society that these procedures
were currently undervalued because of rank-order anomalies, changes in
patient population or incorrect assumptions made in the previous
valuation of the service. However, the RUC-recommended work values for
each service were below the level presented by the specialty society.
The RUC recommended the use of the surveys' 25th percentile work RVUs
for four of the services, CPT codes 57240, 57250, 57500 and 58150, and
the 75th percentile for CPT codes 57260 and 57265. The 75th percentile
was used because the workgroup believed that otherwise there would be a
rank order anomaly between the more complex vagina repair services, CPT
codes 57280 and 57265, and the simpler procedures, CPT codes 57240 and
57250.
The RUC-recommended work values for these services are as follows:
57160 = 0.89 work RVUs; 57240 = 10.56 work RVUs; 57250 = 10.56 work
RVUs; 57260 = 13.50 work RVUs; 57265 = 15.00 work RVUs; 57500 = 1.20
work RVUs; 58120 = 3.27 work RVUs; 58150 = 15.98 work RVUs; and 58720 =
11.34 work RVUs.
CMS Proposed Valuation
We propose to accept the RUC recommendations for these obstetrics
and gynecology services. We initially had concerns with the use of the
surveys' 75th percentile for the recommendation of work RVUs for CPT
codes 57260 and 57265, but in comparison with similar services, we
believe that the RUC recommendations for these services create the
correct rank order, both within the family of codes and with other
similar services.
b. Urology
The American Urological Association (AUA) and the Coalition for the
Advancement of Prosthetic Urology (CAPU) submitted five CPT codes for
review (see Table 19). However, the specialty society subsequently
withdrew four CPT codes (53445, 54400, 54405, and 54411).
Table 19
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
51798.............................. Measurement of post-voiding
residual urine and/or bladder
capacity by ultrasound, non-
imaging.
53445.............................. Insertion of inflatable urethral/
bladder neck sphincter, including
placement of pump, reservoir, and
cuff.
54400.............................. Insertion of penile prosthesis; non-
inflatable (semi-rigid).
54405.............................. Insertion of multi-component,
inflatable penile prosthesis,
including placement of pump,
cylinders, and reservoir.
54411.............................. Removal and replacement of all
components of a multi-component
inflatable penile prosthesis
through an infected field at the
same operative session, including
irrigation and debridement of
infected tissue.
------------------------------------------------------------------------
In addition, we identified seven CPT codes for review because of
possible changes in technology or because the service had never been
reviewed by the RUC (see Table 20). A standard RUC survey with over 30
responses was used for the following codes.
Table 20
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
50590.............................. Lithotripsy, extracorporeal shock
wave.
51720.............................. Bladder instillation of
anticarcinogenic agent (including
detention time).
52000.............................. Cystourethroscopy (separate
procedure).
52204.............................. Cystourethroscopy, with biopsy.
52601.............................. Transurethral electrosurgical
resection of prostate, including
control of postoperative bleeding,
complete (vasectomy, meatotomy,
cystourethroscopy, urethral
calibration and/or dilation, and
internal urethrotomy are
included).
55700.............................. Biopsy, prostate; needle or punch,
single or multiple, any approach.
57288.............................. Sling operation for stress
incontinence (e.g., fascia or
synthetic).
------------------------------------------------------------------------
RUC Recommendations
Of the eight codes presented with survey data, the RUC recommended
maintaining the existing work RVUs for two codes. For CPT code 57288,
the RUC believed that the survey median supported the specialty
society's contention that the work currently associated with the code
is accurate. For CPT code 50590, the RUC believed that the current work
value more accurately reflected the work involved in the service than
did the survey, which increased the work RVUs while decreasing the
physician intra-time substantially.
The RUC recommended decreasing the current work RVUs for CPT code
51720 to reflect the median work RVU from the survey.
The RUC agreed with the specialty society's recommendations for an
increase to the existing RVUs for CPT code 51798. This procedure was
[[Page 37202]]
originally reviewed by the RUC in April 2002 with a recommendation 0.38
work RVUs to reflect the physician work believed to be typically
associated with this procedure. However, in the CY 2002 Physician Fee
Schedule final rule with comment period (66 FR 55246), we contended
that there was no physician work associated with this service and
assigned work RVUs of 0.00. This decision was upheld by the refinement
process that is used to address comments received on the valuation of
new and revised CPT codes and that was discussed in the CY 2004
Physician Fee Schedule final rule with comment period (67 FR 63227).
However, the RUC agreed with the specialty society that this procedure
is performed by physicians and reaffirmed its previous recommendation
of 0.38 work RVUs for this procedure.
The RUC recommended increasing the work RVUs for four codes, but
below the level requested by the specialty society (that is,
recommending work RVUs equal to the surveys' 25th percentile for CPT
codes 52000 and 55700, equal to the median for CPT code 52601 and less
than the 25th percentile for CPT code 52204). The RUC agreed with the
specialty society that these procedures were currently undervalued due
to changes in technology, changes in patient populations and incorrect
assumptions that were made in the previous valuation of the service.
The RUC-recommended work values for these CPT codes for urology
services are as follows: 50590 = 9.08 work RVUs; 51720 = 1.50 work
RVUs; 51798 = 0.38 work RVUs; 52000 = 2.23 work RVUs; 52204 = 2.59 work
RVUs; 52601 = 14.00 work RVUs; 55700 = 2.58 work RVUs; and 57288 =
13.00 work RVUs.
CMS Proposed Valuation
We accept the RUC recommendations for these urology services except
for CPT code 51798. The RUC recommendation for bladder ultrasound was
based on CPT code 79857 (the pelvic ultrasound (nonobstetric)
procedure) as the reference code. (CPT code 76857 should be used if the
urinary bladder alone is imaged, whereas CPT code 51798 should be
utilized if a bladder volume or post-void residual measurement is
obtained without imaging the bladder.) We disagree that this is an
appropriate reference code because the pelvic ultrasound procedure is
very different from a bladder ultrasound procedure. The bladder
ultrasound procedure only results in a ``numerical reading'' of
milliliters of residual urine in the bladder and does not produce an
image on a screen for a physician to interpret like many other
ultrasound procedures (for example, the pelvic ultrasound). Therefore,
we disagree with the RUC recommendation to use the 0.38 physician work
RVUs for the professional component of code 76857 as the work RVUs for
CPT code 51798 because we do not believe this procedure involves
physician work since the machine only produces a numerical reading.
c. Spine Surgery
We identified the CPT codes in Table 21 for the 5-Year Review.
Table 21
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
22520.............................. Percutaneous vertbroplasty, one
vertebral body, unilateral or
bilateral, injection; thoracic.
22554.............................. Arthrodesis, anterior interbody
technique, including minimal
diskectomy to prepare interspace
(other than for decompression);
cervical below C2.
22612.............................. Arthrodesis, posterior or
posterolateral technique, single
level; lumbar (with or without
lateral transverse technique).
22840.............................. Posterior non-segmental
instrumentation (e.g., Harrington
rod technique, pedicle fixation
across one interspace,
atlantoaxial transarticular screw
fixation, sublaminar wiring at C1,
facet screw fixation).
63047.............................. Laminectomy, facetectomy and
foraminotomy (unilateral or
bilateral with decompression of
spinal cord, cauda equina and/or
nerve root(s), (e.g., spinal or
lateral recess stenosis)), single
vertebral segment; lumbar.
63048.............................. Laminectomy, facetectomy and
foraminotomy (unilateral or
bilateral with decompression of
spinal cord, cauda equina and/or
nerve root(s), (e.g., spinal or
lateral recess stenosis)), single
vertebral segment; each additional
segment, cervical, thoracic, or
lumbar (List separately in
addition to code for primary
procedure).
63075.............................. Diskectomy, anterior, with
decompression of spinal cord and/
or nerve root(s), including
osteophytectomy; cervical, single
interspace.
------------------------------------------------------------------------
With approval of the RUC, the specialty society used a modified RUC
survey that included surveys of time (pre-service, intra-service,
immediate post-service), post-operative visits and estimates of total
work. Two reference codes were used to survey the estimates of
intensity and complexity. There were well over 100 responses to each
survey.
RUC Recommendations
The RUC accepted the specialty society's recommendations to
decrease the existing work RVUs for three procedures: CPT codes 22554,
63047 and 63075. The RUC agreed that these procedures were overvalued
due to decreases in the length of stay and physician time. The RUC also
accepted the specialty society's recommendation to maintain the work
associated with CPT codes 22520 and 22840. The RUC agreed with the
specialty society that the survey data collected validated the existing
work RVUs associated with these codes. For CPT codes 22612 and 63048,
the RUC recommended increases in the work RVUs, but less than the
increases requested by the specialty society. The RUC agreed that these
procedures were undervalued due to increases in length of stay and the
incorrect assumptions made in the previous valuation of the service.
The specific RUC-recommended work RVUs were as follows: 22520 =
8.90 work RVUs; 22554 = 16.40 work RVUs; 22612 = 22.00 work RVUs; 22840
= 12.52 work RVUs; 63047 = 14.08 work RVUs; 63048 = 3.55 work RVUs; and
63075 = 18.58 work RVUs.
CMS Proposed Valuation
We accept the work RVUs recommended by the RUC for CPT codes 22520,
22554, 22840, 63047 and 63075. However, we have technical concerns with
the recommendations for CPT codes 22612 and 63048.
The workgroup recommended the survey's 25th percentile for CPT code
22612 to keep the appropriate rank order with the reference service,
CPT code 22595, which is a more complex procedure. However, there was a
typographical error in the information presented by the specialty
society that listed the work RVUs for the reference code as 23.36,
rather than the correct value of 19.36 work RVUs. Therefore, the
recommended work value of 22.00 RVUs is clearly inappropriate and we
[[Page 37203]]
are proposing to maintain the current work RVUs of 20.97 for this
service.
There is an additional typographical error in the specialty society
survey data for CPT code 63048. The summary information lists the
reference code as also being CPT code 63048. Therefore, there is no
information given that compares the respondents' estimates of
complexity and intensity between CPT code 63048 and the reference code.
Because we do not have sufficient information to decide if the
recommended work RVUs are appropriate, we are proposing to maintain the
current work RVUs of 3.26 for CPT code 63048.
d. Spinal Pump Infusion and Stimulators
The American Academy of Pain Medicine (AAPM) and the American
Society of Anesthesiologists (ASA) initially submitted several CPT
codes that were subsequently withdrawn from the 5-Year Review (see
Table 22).
Table 22
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
62350.............................. Implantation, revision or
repositioning of tunneled
intrathecal or epidural catheter,
for long-term medication
administration via an external
pump or implantable reservoir/
infusion pump; without
laminectomy.
62351.............................. Implantation, revision or
repositioning of tunneled
intrathecal or epidural catheter,
for long-term medication
administration via an external
pump or implantable reservoir/
infusion pump; with laminectomy.
62355.............................. Removal of previously implanted
intrathecal or epidural catheter.
62360.............................. Implantation or replacement of
device for intrathecal or epidural
drug infusion; subcutaneous
reservoir.
62361.............................. Implantation or replacement of
device for intrathecal or epidural
drug infusion; non-programmable
pump.
62362.............................. Implantation or replacement of
device for intrathecal or epidural
drug infusion; programmable pump,
including preparation of pump,
with or without programming.
62365.............................. Removal of subcutaneous reservoir
or pump, previously implanted for
intrathecal or epidural infusion.
63650.............................. Percutaneous implantation of
neurostimulator electrode array,
epidural.
63655.............................. Laminectomy for implantation of
neurostimulator electrodes, plate/
paddle, epidural.
63660.............................. Revision or removal of spinal
neurostimulator electrode
percutaneous array(s) or plate/
paddle(s).
63685.............................. Insertion or replacement of spinal
neurostimulator pulse generator or
receiver, direct or inductive
coupling.
63688.............................. Revision or removal of implanted
spinal neurostimulator pulse
generator or receiver.
64550.............................. Application of surface
(transcutaneous) neurostimulator.
64553.............................. Percutaneous implantation of
neurostimulator electrodes;
cranial nerve.
64555.............................. Percutaneous implantation of
neurostimulator electrodes;
peripheral nerve (excludes sacral
nerve).
64560.............................. Percutaneous implantation of
neurostimulator electrodes;
autonomic nerve.
64561.............................. Percutaneous implantation of
neurostimulator electrodes; sacral
nerve (transforaminal placement).
64565.............................. Percutaneous implantation of
neurostimulator electrodes;
neuromuscular.
64573.............................. Incision for implantation of
neurostimulator electrodes;
cranial nerve.
64575.............................. Incision for implantation of
neurostimulator electrodes;
peripheral nerve (excludes sacral
nerve).
64577.............................. Incision for implantation of
neurostimulator electrodes;
autonomic nerve.
64580.............................. Incision for implantation of
neurostimulator electrodes;
neuromuscular.
64581.............................. Incision for implantation of
neurostimulator electrodes; sacral
nerve (transforaminal placement).
64585.............................. Revision or removal of peripheral
neurostimulator electrodes.
64590.............................. Insertion or replacement of
peripheral neurostimulator pulse
generator or receiver, direct or
inductive coupling.
64595.............................. Revision or removal of peripheral
neurostimulator pulse generator or
receiver.
------------------------------------------------------------------------
e. Aneurysm, Epilepsy and Skull Procedures
The American Association of Neurological Surgeons (AANS) and
Congress of Neurological Surgeons (CNS) submitted six CPT codes for
review (see Table 23).
Table 23
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
61537.............................. Craniotomy with elevation of bone
flap; for lobectomy, temporal
lobe, without electrocorticography
during surgery.
61538.............................. Craniotomy with elevation of bone
flap; for lobectomy, temporal
lobe, with electrocorticography
during surgery.
61697.............................. Surgery of complex intracranial
aneurysm, intracranial approach;
carotid circulation.
61698.............................. Surgery of complex intracranial
aneurysm, intracranial approach;
vertebrobasilar circulation.
61700.............................. Surgery of simple intracranial
aneurysm, intracranial approach;
carotid circulation.
61702.............................. Surgery of simple intracranial
aneurysm, intracranial approach;
vertebrobasilar circulation).
------------------------------------------------------------------------
We submitted two CPT codes for review (see Table 24).
Table 24
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
61154.............................. Burr hole(s) with evacuation and/or
drainage of hematoma, extradural
or subdural.
61312.............................. Craniectomy or craniotomy for
evacuation of hematoma,
supratentorial; extradural or
subdural.
------------------------------------------------------------------------
[[Page 37204]]
A standard RUC survey with over 30 responses was used for six of
the codes. The surveys for CPT codes 61537 and 61538 had only 12 and 14
responses, respectively.
RUC Recommendations
The RUC agreed with the specialty society that the existing RVUs
for CPT code 61154 should be maintained because there was no compelling
evidence that the work currently associated with this procedure has
changed. The RUC accepted the specialty society's requested increase to
the existing work RVUs, as reflected by the survey median, for CPT code
61312, agreeing with the specialty society that the increased use of
anticoagulants by these patients has increased the intensity of the
intra-service work. The RUC recommended increasing the work RVUs for
CPT codes 61697, 61698, 61700 and 61702, but at or below the surveys'
25th percentile.
While the workgroup recommended maintaining the current work RVUs
for CPT codes 61537 and 61538, at the subsequent RUC meeting, the
specialty society extracted these codes for discussion and the RUC
recommended the 25th percentile from the surveys for the work RVU.
The RUC-recommended work RVUs for these CPT codes are as follows:
61154 = 14.97 work RVUs; 61312 = 27.00 work RVUs; 61537 = 35.00 work
RVUs; 61538 = 38.00 work RVUs; 61697 = 57.31 work RVUs; 61698 = 64.03
work RVUs; 61700 = 46.01 work RVUs; and 61702 = 54.28 work RVUs.
CMS Proposed Valuation
We accept the RUC-recommended work RVUs for these neurosurgery
services.
4. Radiology, Pathology, and Other Miscellaneous Services
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS-RADIOLOGY, PATHOLOGY, and OTHER
MISC. SERVICES'' at the beginning of your comments.]
a. Pathology
The College of American Pathologists submitted four CPT codes for
review using the rationale that there have been changes in cancer
protocols and the content of work (see Table 25). The specialty society
conducted a full RUC survey for these codes.
Table 25
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
88309.............................. Level VI--Surgical pathology, gross
and microscopic examination; Bone
Resection; Breast, Mastectomy--
with Regional Lymph Nodes; Colon,
Segmental Resection for Tumor;
Colon, Total Resection; Esophagus,
Partial/Total Resection;
Extremity, Disarticulation; Fetus,
with Dissection; Larynx, Partial/
Total Resection--with Regional
Lymph Nodes; Lung--Total/Lobe/
Segment Resection; Pancreas, Total/
Subtotal Resection; Prostate,
Radical Resection; Small
Intestine, Resection for Tumor;
Soft Tissue Tumor, Extensive
Resection; Stomach--Subtotal/Total
Resection for Tumor; Testis,
Tumor; Tongue/Tonsil--Resection
for Tumor; Urinary Bladder,
Partial/Total Resection; Uterus,
with or without Tubes and Ovaries,
Neoplastic; Vulva, Total/Subtotal
Resection.
88321.............................. Consultation and report on referred
slides prepared elsewhere.
88323.............................. Consultation and report on referred
material requiring preparation of
slides.
88325.............................. Consultation, comprehensive, with
review of records and specimens,
with report on referred material.
------------------------------------------------------------------------
RUC Recommendations
The RUC reviewed the specialty's survey results for each code and
believed the specialty society had presented compelling evidence to
change the relative work value for each code because all were
undervalued for the increased physician work now involved in the
services. The RUC believed that the change in work was due to the
increased number and type of slides undergoing review in the typical
case, and, in particular, the number of immunohistochemical slides that
must undergo review. Based on recent literature, the RUC also believed
that the clinical practice of these pathology consultations had
changed. In addition, the RUC agreed with the specialty society that
the survey's 25th percentile reflected the true physician work for each
of the codes.
The RUC-recommended work RVUs for these CPT codes are as follows:
88309 = 2.80 work RVUs, 88321 = 1.63 work RVUs, 88323 = 1.83 work RVUs,
and 88325 = 2.50 work RVUs.
CMS Proposed Valuation
We are in agreement with all of these RUC-recommended work RVUs for
pathology services.
b. Radiation Oncology
We submitted the radiation oncology CPT codes in Table 26 for
review.
Table 26
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
77263.............................. Therapeutic radiology treatment
planning; complex.
77280.............................. Therapeutic radiology simulation-
aided field setting; simple.
77290.............................. Therapeutic radiology simulation-
aided field setting; complex.
77300.............................. Basic radiation dosimetry
calculation, central axis depth
dose calculation, TDF, NSD, gap
calculation, off axis factor,
tissue inhomogeneity factors,
calculation of non-ionizing
radiation surface and depth dose,
as required during course of
treatment, only when prescribed by
the treating physician.
77315.............................. Teletherapy, isodose plan (whether
hand or computer calculated);
complex (mantle or inverted Y,
tangential ports, the use of
wedges, compensators, complex
blocking, rotational beam, or
special beam considerations).
77331.............................. Special dosimetry (e.g., TLD,
microdosimetry) (specify), only
when prescribed by the treating
physician.
77334.............................. Treatment devices, design and
construction; complex (irregular
blocks, special shields,
compensators, wedges, molds or
casts).
77470.............................. Special treatment procedure (e.g.,
total body irradiation, hemibody
radiation, per oral, endocavitary
or intraoperative cone
irradiation).
------------------------------------------------------------------------
[[Page 37205]]
Standard RUC surveys were conducted for these services. The survey
results indicated that the work RVUs for each code should be maintained
at their current level, and the specialty society, the American Society
for Therapeutic Radiology and Oncology (ASTRO), recommended no change
in the work RVU.
RUC Recommendations
The RUC agreed with the survey results and supported the specialty
society's recommendation to maintain the work RVUs. The RUC found no
compelling evidence to change the work RVUs for these CPT codes, and
therefore, recommended maintaining the current work values for these
CPT codes as follows: 77263 = 3.14 work RVUs; 77280 = 0.70 work RVUs;
77290 = 1.56 work RVUs; 77300 = 0.62 work RVUs; 77315 = 1.56 work RVUs;
77331 = 0.87 work RVUs; 77334 = 1.24 work RVUs; and 77470 = 2.09 work
RVUs.
CMS Proposed Valuation
We are in agreement with all of these RUC-recommended work RVUs for
radiology oncology.
c. Radiology
We requested that the CPT codes for radiology services in Table 27
be reviewed.
Table 27
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
70355.............................. Orthopantogram.
71010.............................. Radiologic examination, chest;
single view, frontal.
71020.............................. Radiologic examination, chest, two
views, frontal and lateral.
71260.............................. Computed tomography, thorax; with
contrast material(s).
72192.............................. Computed tomography, pelvis;
without contrast material.
72193.............................. Computed tomography, pelvis; with
contrast material(s).
73100.............................. Radiologic examination, wrist; two
views.
73110.............................. Radiologic examination, wrist;
complete, minimum of three views.
73120.............................. Radiologic examination, hand; two
views.
73130.............................. Radiologic examination, hand;
minimum of three views.
73140.............................. Radiologic examination, finger(s),
minimum of two views.
74000.............................. Radiologic examination, abdomen;
single anteroposterior view.
74020.............................. Radiologic examination, abdomen;
complete, including decubitus and/
or erect views.
74022.............................. Radiologic examination, abdomen;
complete acute abdomen series,
including supine, erect, and/or
decubitus views, single view
chest.
74150.............................. Computed tomography, abdomen;
without contrast material.
74160.............................. Computed tomography, abdomen; with
contrast material(s).
76075.............................. Dual energy x-ray absorptiometry
(DXA), bone density study, one or
more sites; axial skeleton (e.g.,
hips, pelvis, spine).
76700.............................. Ultrasound, abdominal, B-scan and/
or real time with image
documentation; complete.
76830.............................. Ultrasound, transvaginal.
78306.............................. Bone and/or joint imaging; whole
body.
78315.............................. Bone and/or joint imaging; three
phase study.
78465.............................. Myocardial perfusion imaging;
tomographic (SPECT), multiple
studies (including attenuation
correction when performed), at
rest and/or stress (exercise and/
or pharmacologic) and
redistribution and/or rest
injection, with or without
quantification.
78478.............................. Myocardial perfusion study with
wall motion, qualitative or
quantitative study (List
separately in addition to code for
primary procedure).
78480.............................. Myocardial perfusion study with
ejection fraction (List separately
in addition to code for primary
procedure).
------------------------------------------------------------------------
In addition, the American College of Cardiology (ACC) and American
College of Radiology (ACR) recommended four cardiac imaging codes be
sent to the CPT Editorial Panel for review and clarification so that
they may reflect current practice patterns (see Table 28). The RUC
agreed with this recommendation.
Table 28
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
75552.............................. Cardiac magnetic resonance imaging
for morphology; without contrast
material.
75553.............................. Cardiac magnetic resonance imaging
for morphology; with contrast
material.
75554.............................. Cardiac magnetic resonance imaging
for function, with or without
morphology; complete study.
75555.............................. Cardiac magnetic resonance imaging
for function, with or without
morphology; limited study).
------------------------------------------------------------------------
The specialty societies conducted standard RUC surveys for the
remaining services.
RUC Recommendations
The RUC agreed with the survey results and found there was no
compelling evidence to change the work RVUs for CPT codes 70355, 71010,
71020, 71260, 72192, 72193, 73100, 73110, 73120, 73130, 73140, 74000,
74020, 74022, 74150, 74160, 76700, 76830, 78306, 78315, and 78465.
The RUC recommended a reduction in the work RVU for the DXA
service, CPT code 76075, because the workgroup believed that the actual
work is less intense and more mechanical than the specialty society's
description of the work. In addition, the RUC believed that the survey
results provided insufficient evidence to support the current work RVU
associated with CPT code 78478 and also believed that the physician
time was overestimated. The RUC also recommended a reduction in the
work RVUs for CPT code 78480 because it was not in the correct rank
order and was therefore overvalued.
[[Page 37206]]
The RUC-recommended work RVUs for these CPT codes are as follows:
70355 = 0.20 work RVUs; 71010 = 0.18 work RVUs; 71020 = 0.22 work RVUs;
71260 = 1.24 work RVUs; 72192 = 1.09 work RVUs; 72193 = 1.16 work RVUs;
73100 = 0.16 work RVUs; 73110 = 0.17 work RVUs; 73120 = 0.16 work RVUs;
73130 = 0.17 work RVUs; 73140 = 0.13 work RVUs; 74000 = 0.18 work RVUs;
74020 = 0.27 work RVUs; 74022 = 0.32 work RVUs; 74150 = 1.19 work RVUs;
74160 = 1.27 work RVUs; 76075 = 0.20 work RVUs; 76700 = 0.81 work RVUs;
76830 = 0.69 work RVUs; 78306 = 0.86 work RVUs; 78315 = 1.02 work RVUs;
78465 = 1.46 work RVUs; 78478 = 0.50 work RVUs; and 78480 = 0.30 work
RVUs.
CMS Proposed Valuation
We are in agreement with all of these RUC-recommended work RVUs for
radiology services.
d. Endoscopy Procedures
We requested the RUC to review five endoscopy CPT codes because
they had never been reviewed by the RUC (see Table 29). Standard RUC
surveys were conducted.
Table 29
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
43235.............................. Upper gastrointestinal endoscopy
including esophagus, stomach, and
either the duodenum and/or jejunum
as appropriate; diagnostic, with
or without collection of
specimen(s) by brushing or washing
(separate procedure).
43246.............................. Upper gastrointestinal endoscopy
including esophagus, stomach, and
either the duodenum and/or jejunum
as appropriate; with directed
placement of percutaneous
gastrostomy tube.
43750.............................. Percutaneous placement of
gastrostomy tube.
45330.............................. Sigmoidoscopy, flexible;
diagnostic, with or without
collection of specimen(s) by
brushing or washing (separate
procedure).
45378.............................. Colonoscopy, flexible, proximal to
splenic flexure; diagnostic, with
or without collection of
specimen(s) by brushing or
washing, with or without colon
decompression (separate
procedure).
------------------------------------------------------------------------
RUC Recommendations
The RUC agreed with the survey results and found no compelling
evidence to change the work RVUs for any of these services. Therefore,
the RUC recommended the work values for these CPT codes be maintained
as follows: 43235 = 2.39 work RVUs; 43246 = 4.32 work RVUs; 43750 =
4.48 work RVUs; 45330 = 0.96 work RVUs; and 45378 = 3.69 work RVUs.
CMS Proposed Valuation
We are in agreement with the RUC-recommended work RVUs for
endoscopic procedure codes.
e. Neurology, Neuromuscular, and Nervous System
The American Academy of Neurology (AAN), American Clinical
Neurophysiology Society (ACNS), American Association of Neuromuscular
and Electrodiagnostic Medicine (AANEM), and the American Academy of
Physical Medicine and Rehabilitation (AAPMR) submitted five neurology
and neuromuscular CPT codes for this 5-Year Review and AAN and the
American Academy of Pediatrics (AAP) jointly submitted CPT code 62270
(see Table 30).
Table 30
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
62270.............................. Spinal puncture, lumbar,
diagnostic.
95872.............................. Needle electromyography using
single fiber electrode, with
quantitative measurement of
jitter, blocking and/or fiber
density, any/all sites of each
muscle studied.
95925.............................. Short-latency somatosensory evoked
potential study, stimulation of
any/all peripheral nerves or skin
sites, recording from the central
nervous system; in upper limbs.
95926.............................. Short-latency somatosensory evoked
potential study, stimulation of
any/all peripheral nerves or skin
sites, recording from the central
nervous system; in lower limbs.
95927.............................. Short-latency somatosensory evoked
potential study, stimulation of
any/all peripheral nerves or skin
sites, recording from the central
nervous system; in the trunk or
head.
95953.............................. Monitoring for localization of
cerebral seizure focus by
computerized portable 16 or more
channel EEG,
electroencephalographic (EEG)
recording and interpretation, each
24 hours.
------------------------------------------------------------------------
In addition, we requested the RUC to review five neurological CPT
codes (see Table 31).
Table 31
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
95816.............................. Electroencephalogram (EEG);
including recording awake and
drowsy.
95819.............................. Electroencephalogram (EEG);
including recording awake and
asleep.
95861.............................. Needle electromyography; two
extremities with or without
related paraspinal areas.
95900.............................. Nerve conduction, amplitude and
latency/velocity study, each
nerve; motor, without F-wave
study.
95904.............................. Nerve conduction, amplitude and
latency/velocity study, each
nerve; sensory.
------------------------------------------------------------------------
[[Page 37207]]
Standard RUC surveys were conducted for these services. The
specialty societies believed the survey results indicated that the
current work RVUs were either correctly valued or undervalued.
RUC Recommendations
The RUC found no compelling evidence to change the work RVUs for
CPT codes 95816, 95819, 95861, 95900, 95904, 95925, 95926, and 95927.
However, the RUC agreed that there was compelling evidence that CPT
codes 95872 and 95953 were undervalued and recommended increasing their
existing RVUs.
The RUC-recommended work RVUs for these services are as follows:
95816 = 1.08 work RVUs; 95819 = 1.08 work RVUs; 95861 = 1.54 work RVUs;
95872 = 3.00 work RVUs; 95900 = 0.42 work RVUs; 95904 = 0.34 work RVUs;
95925 = 0.54 work RVUs; 95926 = 0.54 work RVUs; 95927 = 0.54 work RVUs;
and 95953 = 3.30 work RVUs.
For CPT code 62270, the RUC believed that there is a bimodal
distribution of physician work associated with the code because there
are two different typical patient types, infants and young children.
The RUC and the specialty societies believed that the infant population
requires less work than in the young child population. The RUC
suggested that it may be reasonable for the specialty societies to
eventually consider splitting the code into the two typical patient
types to capture any differences in physician work. However, for the
current CPT code 62270, the RUC recommended that it should be valued
higher and recommended a work RVU of 1.37.
CMS Proposed Valuation
We are in agreement with all of the RUC-recommended work RVUs for
neurology, neuromuscular and nervous system services except for the
recommendation for CPT code 95872. We have concerns that the work
recommendation for this service, which was based on the survey's 75th
percentile for work, is not the correct valuation and is inappropriate
for this service. We calculated the pre-service and post-service work
RVU using the surveyed physician time data. Then, we subtracted the
surveyed intra-service time from the current time. Next, we multiplied
this difference in time by the calculated IWPUT using the specialty
recommended total work RVUs to determine an intra-service work RVU.
Adding the calculated work RVUs resulted in a work RVU of slightly less
than 2.0, which is close to the same value as the survey median work
RVU. In accordance with this analysis and the survey median, we are
recommending a work RVU of 2.00.
f. Pulmonary Medicine
We requested the RUC to review three pulmonary medicine CPT codes
(see Table 32).
Table 32
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
31622.............................. Bronchoscopy, rigid or flexible,
with or without fluoroscopic
guidance; diagnostic, with or
without cell washing (separate
procedure).
94010.............................. Spirometry, including graphic
record, total and timed vital
capacity, expiratory flow rate
measurement(s), with or without
maximal voluntary ventilation.
94657.............................. Ventilation assist and management,
initiation of pressure or volume
preset ventilators for assisted or
controlled breathing; subsequent
days.
------------------------------------------------------------------------
Standard RUC surveys were conducted. The specialty societies
believed the survey results indicated that the current work RVUs were
either correctly valued or undervalued.
RUC Recommendations
The RUC reviewed the survey results and recommendations from the
specialty society for CPT codes 31622 and 94010 and found no compelling
reason to change the work RVUs for these codes. However, the RUC agreed
with the specialty society that the time data elements from the survey
results reflected the typical patient encounter.
The RUC did find compelling evidence to support the specialty
society's recommendation and survey work value results for CPT code
94657. However, the RUC determined that a rank order anomaly would be
created with CPT code 94656 if the recommended value for CPT code 94657
was adopted. Therefore, the RUC recommended that this code be referred
to the CPT Editorial Panel.
The RUC-recommended work RVUs for these codes are as follows: 31622
= 2.78 work RVUs and 94010 = 0.17 work RVUs.
CMS Proposed Valuation
We are in agreement with these RUC-recommended work RVUs for
pulmonary medicine services.
g. Miscellaneous Services
(i) Anesthesia
The ASA requested that the RUC review code 00797, Anesthesia for
intraperitoneal procedures in upper abdomen including laparoscopy;
gastric restrictive procedure for morbid obesity. The ASA believed that
the results of the standard RUC survey conducted by the specialty
society indicated the physician work was undervalued for this code.
RUC Recommendations
The RUC reviewed the survey results and specialty society
recommendation and agreed with its recommended median base unit value
and physician time for the code. The RUC recommended base unit
valuation for this service was 11.00.
CMS Proposed Valuation
We are in agreement with the RUC recommendation for CPT code 00797.
(ii) Allergy and Immunology
The Joint Council of Allergy, Asthma, and Immunology (JCAAI) and
the American Academy of Otolaryngic Allergy (AAOA) submitted five codes
without work relative values for this 5-Year Review based on the
rationale that physician work was inherent in the service (see Table
33). The specialties subsequently withdrew CPT codes 95115 and 95117
from consideration.
Table 33
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
95004.............................. Percutaneous tests (scratch,
puncture, prick) with allergenic
extracts, immediate type reaction,
specify number of tests.
[[Page 37208]]
95024.............................. Intracutaneous (intradermal) tests
with allergenic extracts,
immediate type reaction, specify
number of tests.
95027.............................. Intracutaneous (intradermal) tests,
sequential and incremental, with
allergenic extracts for airborne
allergens, immediate type
reaction, specify number of tests.
95115.............................. Professional services for allergen
immunotherapy not including
provision of allergenic extracts;
single injection.
95117.............................. Professional services for allergen
immunotherapy not including
provision of allergenic extracts;
two or more injections.
------------------------------------------------------------------------
In addition, we requested the RUC to review the immunotherapy CPT
codes in Table 34 because they had never been reviewed by the RUC.
Standard RUC surveys were conducted.
Table 34
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
95144.............................. Professional services for the
supervision of preparation and
provision of antigens for allergen
immunotherapy, single dose vial(s)
(specify number of vials).
95165.............................. Professional services for the
supervision of preparation and
provision of antigens for allergen
immunotherapy; single or multiple
antigens (specify number of
doses).
------------------------------------------------------------------------
RUC Recommendations
The RUC reviewed the specialty society recommendations, and survey
results recommended that CPT codes 95004, 95024, and 95027 be referred
to the CPT Editorial Panel for clarification and possible revision. The
RUC recommended that the current work RVUs be maintained for CPT codes
95144 and 95165, because there was no compelling evidence for a change.
The RUC-recommended work RVUs for these CPT codes are: 95144 = 0.06
work RVUs; and 95165 = 0.06 work RVUs.
CMS Proposed Valuation
We are in agreement with these RUC-recommended work RVUs for
allergy and immunology services.
(iii) Pediatric codes
The AAP requested that the RUC review eight pediatric-related CPT
codes for this 5-Year Review (see Table 35). However, two of these CPT
codes (90473 and 90474) were subsequently withdrawn by AAP. The
remaining six codes were referred to the CPT Editorial Panel for
review.
Table 35
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
54150.............................. Circumcision, using clamp or other
device; newborn.
54152.............................. Circumcision, using clamp or other
device; except newborn.
90465.............................. Immunization administration under 8
years of age (includes
percutaneous, intradermal,
subcutaneous, or intramuscular
injections) when the physician
counsels the patient/family; first
injection (single or combination
vaccine/toxoid), per day.
90466.............................. Immunization administration under 8
years of age (includes
percutaneous, intradermal,
subcutaneous, or intramuscular
injections) when the physician
counsels the patient/family; each
additional injection (single or
combination vaccine/toxoid), per
day (List separately in addition
to code for primary procedure).
90467.............................. Immunization administration under
age 8 years (includes intranasal
or oral routes of administration)
when the physician counsels the
patient/family; first
administration (single or
combination vaccine/toxoid), per
day.
90468.............................. Immunization administration under
age 8 years (includes intranasal
or oral routes of administration)
when the physician counsels the
patient/family; each additional
administration (single or
combination vaccine/toxoid), per
day (List separately in addition
to code for primary procedure).
90473.............................. Immunization administration by
intranasal or oral route; one
vaccine (single or combination
vaccine/toxoid).
90474.............................. Immunization administration by
intranasal or oral route; each
additional vaccine (single or
combination vaccine/toxoid) (List
separately in addition to code for
primary procedure).
------------------------------------------------------------------------
(iv) Cardiology-Related Services
We requested that the RUC review five cardiology-related CPT codes
(see Table 36). The specialty societies believed that the standard RUC
survey results indicated that the work RVUs for each code should be
either maintained or decreased from their current level.
Table 36
------------------------------------------------------------------------
CPT code Description
------------------------------------------------------------------------
33208.............................. Insertion or replacement of
permanent pacemaker with
transvenous electrode(s); atrial
and ventricular.
93010.............................. Electrocardiogram, routine ECG with
at least 12 leads; interpretation
and report only.
93015.............................. Cardiovascular stress test using
maximal or submaximal treadmill or
bicycle exercise, continuous
electrocardiographic monitoring,
and/or pharmacological stress;
with physician supervision, with
interpretation and report.
93018.............................. Cardiovascular stress test using
maximal or submaximal treadmill or
bicycle exercise, continuous
electrocardiographic monitoring,
and/or pharmacological stress;
interpretation and report only.
[[Page 37209]]
93325.............................. Doppler echocardiography color flow
velocity mapping (List separately
in addition to codes for
echocardiography).
------------------------------------------------------------------------
RUC Recommendations
The RUC reviewed the survey results and found no compelling
evidence to change the work RVUs for CPT codes 33208, 93010, 93015, and
93018. However, CPT code 93325 was referred to the CPT Editorial Panel
by the RUC with the recommendation that this service be bundled with
CPT code 93307, Echocardiography, transthoracic, real-time with image
documentation (2D) with or without M-mode recording; complete.
The RUC-recommended work RVUs for these CPT codes are as follows:
33208 = 8.12 work RVUs; 93010 = 0.17 work RVUs; 93015 = 0.75 work RVUs;
and 93018 = 0.30 work RVUs.
CMS Proposed Valuation
We are in agreement with these RUC-recommended work RVUs for
cardiology related services.
5. Evaluation and Management (E/M) Services
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS--EVALUATION AND MANAGEMENT
SERVICES'' at the beginning of your comments.]
A consortium of 27 organizations submitted a consensus comment
letter stating that the work of E/M services has changed significantly
since the E/M codes were reviewed during the first 5-Year Review and
requested that the E/M codes be reviewed (see Table 37).
In addition, the following specialty societies submitted requests
that individual E/M CPT codes be reviewed: The American Academy of
Family Physicians (AAFP), the American Medical Directors Association
(AMDA), the American Geriatric Society (AGS), the American Association
for Geriatric Psychiatry (AAGP), the ASA, and the American Academy of
Home Care Physicians (AAHCP).
[[Page 37210]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.039
[[Page 37211]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.040
[[Page 37212]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.041
[[Page 37213]]
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BILLING CODE 4120-01-C
Standard RUC surveys of the E/M services were conducted by a
coalition of medical specialty societies. Recommendations of the
coalition, as well as comments from the coalition of surgical
specialties, were considered by the RUC workgroup.
RUC Recommendations
The RUC E/M workgroup conferred via conference call throughout the
summer of 2005 and reviewed previous studies and methodologies used to
evaluate the physician work related to the E/M services. At the first
meeting in August of 2005, the workgroup considered the recommendations
of the coalition of medical specialty societies, as well as the
comments of the coalition of surgical specialties that countered the
arguments presented regarding increased physician work. After extensive
discussion, the workgroup agreed that there was evidence that incorrect
assumptions were made in the previous valuation of these services. The
workgroup reviewed each E/M code extensively, reviewing the survey from
the coalition of medical specialties, comparing the codes to reference
codes and considering comments from the surgical coalition and other
meeting attendees.
At the RUC meeting in October 2005, the RUC agreed that there was
compelling evidence to review the E/M services because of evidence that
incorrect assumptions were made in the previous valuation of the
services. The RUC approved final recommendations for 26 of these codes,
interim recommendations for six codes (CPT codes 99222, 99223, 99232,
99233, 99291, and 99292) and postponed the review of three codes (CPT
codes 99213, 99214, and 99215) to the February 2006 meeting.
At the February 2006 meeting, the RUC reached consensus on the
recommended work values for all the
[[Page 37218]]
outstanding E/M codes. As an example of the RUC review process, we are
including the RUC notes on the rationale used to recommend a revised
work value for CPT code 99213, the mid-level office visit, which is
also the most frequently billed code in the PFS:
``The RUC agreed that the compelling evidence to review CPT code
99213 is that incorrect assumptions were made in the previous
valuation of CPT code 99213 (that is, the assumptions made by
Harvard and CMS are flawed). The RUC extensively discussed CPT code
99213 (physician time: pre- = 3, intra- = 15, and post- = 5) and
agreed that this code is slightly more work than CPT code 99202
(recommended work RVU = 0.88; physician time: pre- = 2, intra- = 15,
and post- = 5). It was noted the content for CPT code 99213
represents a higher level of intensity as the medical decision
making is ``low'' for CPT code 99213, versus ``straightforward'' for
CPT code 99202. CMS also provided utilization data that indicated
that diagnosis and number of diagnosis were more significant for CPT
code 99213 than CPT code 99202. Finally, the survey respondents
agreed with this relationship, as the survey median work RVU for
``all'' survey respondents was 1.10 for CPT code 99213 and 1.05 for
CPT code 99202. Utilizing this relationship and the recommended work
RVU of 0.88 for CPT code 99202, the RUC determined that a work RVU
of 0.92 for CPT code 99213 is appropriate. In addition, the RUC
agreed that CPT code 99213 is similar in work to CPT code 93307
Echocardiography, transthoracic, real-time with image documentation
(2D) with or without M-mode recording; complete (work RVU = 0.92,
physician time: pre- = 5, intra- = 18, and post- = 5), which is a
code included on the RUC's Multi-Specialty Points of Comparison
(MPC). It was also noted that the 25th percentile of the `all'
survey respondent, weighted survey data was 0.95 RVUs. The RUC
recommends a work RVU of 0.92 for CPT code 99213 (physician time:
pre- = 3, intra- = 15, and post- = 5).''
The RUC also recommended that the full increase for these codes be
incorporated into the surgical global periods for each CPT code with a
global period of 010 and 090.
Based on a review of the survey information, the RUC recommended
that the work RVUs for the following CPT codes be maintained: 99201 =
0.45 work RVUs; 99202 = 0.88 work RVUs; 99203 = 1.34 work RVUs; 99211 =
0.17 work RVUs; 99212 = 0.45 work RVUs; 99238 = 1.28 work RVUs; and
99241 = 0.64 work RVUs.
The RUC also recommended that the work RVUs for the following CPT
codes be increased: 99204 = 2.30 work RVUs; 99205 = 3.00 work RVUs;
99213 = 0.92 work RVUs; 99214 = 1.42 work RVUs; 99215 = 2.00 work RVUs;
99221 = 1.88 work RVUs; 99222 = 2.56 work RVUs; 99223 = 3.78 work RVUs;
99231 = 0.76 work RVUs; 99232 = 1.39 work RVUs; 99233 = 2.00 work RVUs;
99239 = 1.90 work RVUs; 99242 = 1.34 work RVUs; 99243 = 1.88 work RVUs;
99244 = 3.02 work RVUs; 99245 = 3.77 work RVUs; 99251 = 1.00 work RVUs;
99252 = 1.50 work RVUs; 99253 = 2.27 work RVUs; 99254 = 3.29 work RVUs;
99255 = 4.00 work RVUs; 99281 = 0.45 work RVUs; 99282 = 0.88 work RVUs;
99283 = 1.34 work RVUs; 99284 = 2.56 work RVUs; 99285 = 3.80 work RVUs;
99291 = 4.50 work RVUs; and 99292 = 2.25 work RVUs.
The RUC also noted that twelve E/M codes (nursing facility and
domiciliary care) originally submitted had been deleted by CPT and
replaced by new CPT codes that were reviewed by the RUC last year.
These new CPT codes were included in the CY 2006 PFS final rule with
comment period (70 FR 70116) and the associated RVUs were considered
interim and subject to comment. Therefore, these new CPT codes were not
included as part of the 5-Year Review.
CMS Proposed Valuation
We are in agreement with these RUC recommended work RVUs for E/M
services. We also agree with the recommendation that the full increase
for these codes should be incorporated into the surgical global periods
for each CPT code with a global period of 010 and 090.
6. Cardiothoracic Surgery
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS--CARDIOTHORACIC SURGERY'' at the
beginning of your comments.]
a. Congenital Codes
The STS/ American Association for Thoracic Surgery (AATS) submitted
the congenital cardiac surgical CPT codes for review (see Table 38).
Table 38
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
33414.............................. Repair of left ventricular outflow
tract obstruction by patch
enlargement of the outflow tract.
33416.............................. Ventriculomyotomy (-myectomy) for
idiopathic hypertrophic subaortic
stenosis (e.g., asymmetric septal
hypertrophy).
33505.............................. Repair of anomalous coronary artery
from pulmonary artery origin; with
construction of intrapulmonary
artery tunnel (Takeuchi
procedure).
33665.............................. Repair of intermediate or
transitional atrioventricular
canal, with or without
atrioventricular valve repair.
33684.............................. Closure of ventricular septal
defect, with or without patch;
with pulmonary valvotomy or
infundibular resection
(acyanotic).
33688.............................. Closure of ventricular septal
defect, with or without patch;
with removal of pulmonary artery
band, with or without gusset.
33771.............................. Repair of transposition of the
great arteries with ventricular
septal defect and subpulmonary
stenosis; with surgical
enlargement of ventricular septal
defect.
33779.............................. Repair of transposition of the
great arteries, aortic pulmonary
artery reconstruction (e.g.,
Jatene type); with removal of
pulmonary band.
33781.............................. Repair of transposition of the
great arteries, aortic pulmonary
artery reconstruction (e.g.,
Jatene type); with repair of
subpulmonic obstruction.
------------------------------------------------------------------------
The commenters stated that at the second 5-Year Review, many of the
more common congenital cardiac surgical codes were reviewed, and the
values were adjusted. However, at that time, these much less commonly
performed congenital cardiac surgical codes were not surveyed due to
resource and time constraints. The commenter believed that this has
created rank order anomalies within these families of codes.
Standard RUC surveys were conducted for the services in Table 38.
However, there was a low response rate that was attributable to these
procedures being infrequently performed by a small number of surgeons.
RUC Recommendations
The RUC believed that the current work RVUs for the codes presented
created rank order anomalies in terms of the physician work relative
value, but, during the review, the RUC agreed that a number of the
reference procedures had inaccurate physician times. When the reference
code times were compared
[[Continued on page 37219]]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
]
[[pp. 37219-37268]] Medicare Program; Five-Year Review of Work Relative Value Units
Under the Physician Fee Schedule and Proposed Changes to the Practice
Expense Methodology
[[Continued from page 37218]]
[[Page 37219]]
with the surveyed times for the codes under review, the RUC noted
inconsistencies in all time segments, including intra-service time. The
RUC reviewed the survey data and the data for the reference codes, and
made recommendations for work RVUs to place the surveyed codes in
proper rank order. Recommendations for work RVUs reflected the survey's
25th percentile, the median survey value, or the time-adjusted survey
data, which was based on time adjustments for certain portions of the
service when compared to the reference codes. Due to concern about the
accuracy of time for some of the reference codes, the RUC also
recommended that the specialty society conduct future surveys for
physician time only for CPT codes 33660, 33670, 33506, 33770, and
33780. However, the RUC agreed that the new 5-Year Review values and
times could not be used to justify changes in the relative values of
the reference services.
The RUC-recommended work RVUs for these CPT codes are as follows:
33414 = 36.52 work RVUs; 33416 = 34.25 work RVUs; 33505 = 36.00 work
RVUs; 33665 = 32.98 work RVUs; 33684 = 32.50 work RVUs; 33688 = 32.88
work RVUs; 33771 = 38.50 work RVUs; 33779 = 41.00 work RVUs; and 33781
= 41.00 work RVUs.
b. Adult Cardiac and General Thoracic Codes
The STS/ATTS submitted 46 adult cardiac CPT codes for review and 27
general thoracic CPT codes for review but subsequently withdrew two CPT
codes (32095 and 35600). The specialty believed many of these CPT codes
needed to be reviewed due to the rank order anomalies that exist in
these families of CPT codes (see Table 39).
We submitted two CPT codes for review, 32020 and 39400; however, no
specialty expressed an interest in conducting a survey for CPT code
32020 so there was no RUC recommendation forwarded for this service.
(See Table 39 for all codes submitted.)
BILLING CODE 4120-01-P
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BILLING CODE 4120-01-C
[[Page 37224]]
The RUC had previously approved a building-block methodology based
on the STS database, which would provide a mean intra-service time for
the adult cardiac and general thoracic codes, as well as the procedure-
specific length of stay. Two intensity surveys were also conducted and
the final recommended intensity was an average of the two survey
results. The remaining pre-service and post-service inputs were derived
through a panel of cardiac surgeons.
The add-on CPT codes (33141, 33517 through 33523 and 33530) were
evaluated by subtracting the time data for the base code from the time
data for the combined base and add-on codes, with the results weighted
for frequency of occurrence.
RUC Recommendations
The RUC workgroup reviewed the data elements for each code on a
code-by-code basis. Most of the discussion focused on the number and
level of post-operative visits, as well as the pre-service time. For
the adult cardiac and general thoracic codes, the RUC agreed that the
pre-service time was overstated and needed to reflect previously
approved RUC pre-service times. Also, the RUC questioned the total
times allocated to the codes when compared to a normal surgical work
week. The workgroup developed a pre-service time standard that was used
for a majority of the codes. This standard consisted of 60 minutes for
evaluation, 15 minutes for positioning, and 20 minutes for scrub dress
and wait time. For emergent procedures, the pre-service times were set
at 10 minutes for evaluation, 12 minutes for positioning, and 15
minutes for scrub dress and wait time. The immediate post-service time
was examined in conjunction with other visits on the same day of
surgery. For most of the codes, the immediate post-service time was
standardized at 40 minutes.
The intra-service times were derived from the STS database with
mean times used for the adult cardiac codes and median times for the
general thoracic codes. Because the general thoracic codes have a much
lower number of cases in the database, the STS believed that the median
was more appropriate. The RUC agreed with the specialty society that
critical care visits should be used in the STS building-block
methodology for all of the adult cardiac codes and for 13 of the
general thoracic codes.
The assignment of the level of critical care services was
recommended for each code based on the STS panel's knowledge and
experience in caring for these patients, within the framework of the
duration of mechanical ventilation and the length of intensive care
unit (ICU) stay provided by appropriate data in the STS database. The
RUC also made changes to the hospital visits on a line-by-line basis,
but used the STS length of stay data as a guide. Generally, the level
of hospital visits was reduced so that the total number of visits
equaled the length of stay. On the day of discharge, the RUC assigned a
discharge day management code as the only service provided on that day.
During the review of various cardiothoracic surgery procedures, the
RUC determined that several of the reference service codes used in the
analysis of surveyed codes (specifically, CPT codes 33506, 33660,
33670, 33770 and 33780) had inaccurate physician times associated with
them. The RUC instructed the specialty society to conduct a survey of
time for these reference codes; however, these times could not be used
to justify new relative values.
The RUC recommended work RVUs for these CPT codes were as follows:
General Thoracic codes: 32141 = 23.90 work RVUs; 32442 = 51.45 work
RVUs; 32445 = 57.74 work RVUs; 32484= 23.25 work RVUs; 32486 = 39.44
work RVUs; 32488 = 38.95 work RVUs; 32540 = 26.42 work RVUs; 32651 =
16.64 work RVUs; 32652 = 26.35 work RVUs; 32653 = 16.24 work RVUs;
32654 = 17.73 work RVUs; 32655 = 14.69 work RVUs; 32657 = 11.90 work
RVUs; 32662 = 14.29 work RVUs; 32663 = 23.00 work RVUs; 32665 = 19.56
work RVUs; 32815 = 42.94 work RVUs; 39220 = 18.40 work RVUs; 39400 =
7.61 work RVUs; 43108 = 76.55 work RVUs; 43113 = 73.23 work RVUs; 43116
= 87.16 work RVUs; 43118 = 61.08 work RVUs; 43121 = 46.59 work RVUs;
43123 = 76.14 work RVUs; 43124 = 60.61 work RVUs; 43135 = 24.20 work
RVUs. As noted above in this section, there was no RUC recommendation
forwarded for CPT code 32020.
Adult Cardiac codes: 33140 = 25.49 work RVUs; 33141 = 2.43 work
RVUs; 33300 = 40.03 work RVUs; 33305 = 70.21 work RVUs; 33400 = 38.33
work RVUs; 33405 = 37.82 work RVUs; 33406 = 49.18 work RVUs; 33410 =
42.91 work RVUs; 33411 = 56.91 work RVUs; 33413 = 56.19 work RVUs;
33415 = 34.58 work RVUs; 33425 = 45.97 work RVUs; 33426 = 39.78 work
RVUs; 33427 = 41.82 work RVUs; 33430 = 46.45 work RVUs; 33460 = 40.19
work RVUs; 33463 = 50.93 work RVUs; 33464 = 40.30 work RVUs; 33465 =
45.72 work RVUs; 33474 = 36.39 work RVUs; 33475 = 39.39 work RVUs;
33510 = 31.75 work RVUs; 33511 = 35.22 work RVUs; 33512 = 40.26 work
RVUs; 33513 = 41.65 work RVUs; 33514 = 44.36 work RVUs; 33516 = 46.04
work RVUs; 33517 = 3.36 work RVUs; 33518 = 7.41 work RVUs; 33519 = 9.91
work RVUs; 33521 = 12.01 work RVUs; 33522 = 13.53 work RVUs; 33523 =
15.39 work RVUs; 33530 = 9.78 work RVUs; 33533 = 30.85 work RVUs; 33534
= 36.98 work RVUs; 33535 = 41.85 work RVUs; 33536 = 45.53 work RVUs;
33542 = 44.20 work RVUs; 33545 = 52.49 work RVUs; 33641 = 27.71 work
RVUs; 33860 = 55.45 work RVUs; 33863 = 55.10 work RVUs; 33945 = 80.84
work RVUs; and 35820 = 32.24 work RVUs.
CMS Proposed Valuation
We are in agreement with the RUC-recommended work RVUs for the
congenital cardiac surgery services.
As mentioned above, the general thoracic and adult cardiac surgery
codes submitted to the RUC for review did not undergo the standard RUC
survey methodology. Rather, the data pertaining to these codes were
derived from the STS database, a voluntary registry developed by the
STS that has reportedly captured data on approximately 70 percent of
all cardiac surgical procedures in the United States.
We believe that the STS database, which also captures outcomes
data, is a significant tool in the effort to improve the quality of
patient care and we hope that this kind of data collection will be
emulated by other specialties. We also believe that the time and visit
data contained in this database could be a useful adjunct to the RUC's
validation of the standard RUC survey results. However, we have
significant concerns with its use as a tool to derive work RVUs without
reference to a standard RUC survey. We have questions regarding the
representativeness of the data in the STS database because it is
unclear what percentage of the patients in the database is derived from
academic medical centers versus community hospitals or whether the
cases are selectively reported (for example, does the case mix contain
a disproportionate number of complex cases?) We also would like
information regarding the type of hospitals that chose not to
participate in the database. Additionally, while we recognize this
database has collected large numbers of cases for cardiac services, the
database was not robust for the non-cardiac thoracic service.
In addition, we would also want to know the median values, as well
as the mean values, for the intra-service time for the adult cardiac
services because the RUC's standard methodology is based on median
values. Therefore, we are concerned about maintaining the relativity
between these services and those where the median values were
[[Page 37225]]
used to recommend the work RVUs. We also believe the median is a better
estimate of central tendency when more extreme cases occur in either
direction.
However, our main concern is not with the time data itself, but
rather with how these data were translated into work RVUs because work
RVUs are not calculated solely on the basis of the time it takes to
perform a given procedure. The other equally important variable is the
intensity of the procedure, which is a measure of the technical skill,
mental effort, and psychological stress involved in performing the
procedure. The standard RUC survey captures these data by comparisons
to the key reference procedure, asking the responders to rate both the
surveyed and reference codes on the specific intensity measures, using
a scale of one to five.
The presenting specialties used an entirely different methodology
to arrive at their intensity measures by estimating the IWPUT of each
service. The presenters stated that the IWPUT was estimated using two
methods: IWPUT magnitude estimation and RASCH paired analysis for each
code. According to the presenters, the IWPUT magnitude estimation
produced direct IWPUT values and the RASCH analysis produced arbitrary
scalar values as estimates of CPT code intensity rank and dispersion.
These values were converted to IWPUT values by regression of the
results to obtain slope, and offset of the results was based on the
median value of the magnitude estimation survey. Each RASCH scalar was
then converted to IWPUT with the formula y = mx + b where m is the
slope and b is the y-intercept.
Though we appreciate the effort that went into such a method, we
have several concerns with this approach: (1) We do not believe that
the RASCH paired analysis methodology has been approved by the RUC, and
has certainly not yet been accepted by CMS as a method for calculating
the intensity of a service; (2) we also would want to know more about
the surveys themselves, as well as the instructions to the surveyees,
before agreeing to any work RVUs based on this method; and (3) we are
concerned that the relativity of the fee schedule could be compromised
by using such a different method to determine the work relative values
of a small number of codes because current work RVUs for other services
are not based on this methodology. In addition, we have a further
concern regarding the appropriate relativity of the RUC recommendations
for these thoracic and cardiac procedures. If we assume the times in
the STS database are accurate, by comparing the intra-service times in
the STS database to the median times from the surveys done in 2000 for
these codes, it appears that surgeons might often underestimate the
time spent in the intra-service period. If this is actually the case
here, then this could also be true for other services that would not
have the benefit of this database. The acceptance of the work RVUs
derived by this methodology could then produce rank order anomalies
with codes done by other specialties and the relativity of the fee
schedule could be compromised by the selective use of this database.
We would not want to see the RUC abandon its survey methodology,
unless a better approach can be found that can be applied to all
services. We understand that the standard RUC survey process is not
perfect, but it does provide an even playing field for all specialties
and we would be concerned if each specialty was allowed to develop its
own unique method for estimating work RVUs. Therefore, we would
recommend that the RUC review this issue again to determine the
appropriate use of data sources other than the RUC survey.
It is our responsibility to assure all medical specialties that we
will review and evaluate their services using an approach that is
accepted by the AMA and CMS. However, we do not know how to use this
STS data to compare the relativity of these thoracic and cardiac
surgery services to services of similar intensity in other clinical
areas. Therefore, we are proposing not to accept the RUC work RVU
recommendations for these codes. Because the RUC did approve the use of
the STS database and the specialty societies put forth a substantial
effort to present their data to the RUC, based on that approval, we
also do not think it would be appropriate to propose maintaining the
current values.
We believe the standard RUC survey process used to evaluate the
cardiac surgery codes during the second 5-Year Review had the correct
incremental increase in work RVUs between codes, as well as the
appropriate intensity for each code. We have calculated the IWPUT for
the current values for all of the cardiac codes submitted for review
(excluding the add-on codes discussed below) and multiplied the IWPUT
of each code with the time proposed for that code to yield a new RVU
for that service. We also calculated an IWPUT for the thoracic codes
using the current values. Because we do not have survey data, we
believe this is a fair way to value the proposed codes while
maintaining the incremental increase between codes. We look forward to
comments on this issue and would be willing to consider future RUC
recommendations if the specialty societies wish to submit standard RUC
surveys for these codes.
CPT codes 33517, 33518, 33519, 33521, 33522, and 33523 are coronary
surgery bypass codes using venous grafts and arterial grafts. These are
add-on codes used in conjunction with the primary code, a coronary
arterial graft. Add-on codes reflect the additional intra-service time
required to perform the additional venous anastomoses. These codes do
not contain post-service time, critical care time, or hospital care.
When presented to the RUC, this series of codes had critical care time
and inpatient hospital care time added to the total value of the code.
We will maintain the current RVU valuation for CPT codes 33517, 33518,
33519, 33521, 33522, and 33523.
Therefore, the proposed work RVUs for these CPT codes are as
follows: 32141 = 13.98 work RVUs; 32442 = 32.86 work RVUs; 32445 =
34.95 work RVUs; 32484 = 20.66 work RVUs; 32486 = 28.40 work RVUs;
32488 = 28.87 work RVUs; 32540 = 19.94 work RVUs; 32651 = 14.26 work
RVUs; 32652 = 20.75 work RVUs; 32653 = 18.05 work RVUs; 32654 = 15.82
work RVUs; 32655 = 13.59 work RVUs; 32657 = 13.63 work RVUs; 32662 =
16.42 work RVUs; 32663 = 18.44 work RVUs; 32665 = 15.52 work RVUs;
32815 = 31.17 work RVUs; 33140 = 19.97 work RVUs; 33141 = 4.83 work
RVUs; 33300 = 25.09 work RVUs; 33305 = 27.05 work RVUs; 33400 = 36.23
work RVUs; 33405 = 36.64 work RVUs; 33406 = 45.54 work RVUs; 33410 =
35.36 work RVUs; 33411 = 52.12 work RVUs; 33413 = 51.76 work RVUs;
33414 = 36.52 work RVUs; 33415 = 27.11 work RVUs; 33416 = 34.25 work
RVUs; 33425 = 34.55 work RVUs; 33426 = 37.95 work RVUs; 33427 = 39.94
work RVUs; 33430 = 45.57 work RVUs; 33460 = 23.56 work RVUs; 33463 =
36.59 work RVUs; 33464 = 26.78 work RVUs; 33465 = 28.75 work RVUs;
33474 = 23.01 work RVUs; 33475 = 41.97 work RVUs; 33505 = 36.00 work
RVUs; 33510 = 30.37 work RVUs; 33511 = 31.51 work RVUs; 33512 = 35.16
work RVUs; 33513 = 36.12 work RVUs; 33514 = 36.93 work RVUs; 33516 =
38.39 work RVUs; 33517 = 2.57 work RVUs; 33518 = 4.84 work RVUs; 33519
= 7.11 work RVUs; 33521 = 9.39 work RVUs; 33522 = 11.65 work RVUs;
33523 = 13.93 work RVUs; 33530 = 5.85 work RVUs; 33533 = 34.63 work
RVUs; 33534 = 36.06 work RVUs; 33535 = 38.73 work RVUs; 33536 = 38.04
work RVUs; 33542 = 28.81 work RVUs; 33545 = 36.72 work RVUs; 33641 =
26.70 work RVUs; 33665 = 32.98 work RVUs; 33684 = 32.50 work
[[Page 37226]]
RVUs; 33688 = 32.88 work RVUs; 33771 = 38.50 work RVUs; 33779 = 41.00
work RVUs; 33781 = 41.00 work RVUs; 33860= 39.29 work RVUs; 33863 =
44.93 work RVUs; 33945 = 42.04 work RVUs; 35820 = 25.53 work RVUs;
39220 = 17.39 work RVUs; 39400 = 5.60 work RVUs; 43108 = 57.20 work
RVUs; 43113 = 40.41 work RVUs; 43116 = 65.85 work RVUs; 43118 = 46.37
work RVUs; 43121 = 41.80 work RVUs; 43123 = 57.14 work RVUs; 43124 =
56.51 work RVUs; and 43135 = 20.52 work RVUs.
For CPT code 32020, Tube thoracostomy with or without water seal
(e.g., for abscess, hemothorax, empyema)(separate procedure), although
there was no RUC recommendation provided due to the lack of a level
interest for surveying this code, we continue to believe that this
service is misvalued. This code was presented to the RUC during the two
previous 5-Year Reviews. Based on a lack of compelling evidence, the
RUC recommended maintaining the work RVUs, and we accepted this
recommendation. However, we believe that since valuation of this CPT
code continues to be based on Harvard time data, changes in practice
and technology have not been incorporated, leading to an overvaluation
of this service. The Harvard time data for this service includes: Pre-
service time of 46 minutes, intra-service time of 24 minutes, post-
service time of 25 minutes, 9 minutes for ICU time, 15 minutes for
hospital days, and 2 minutes for office visits for a total time of 121
minutes. We believe that CPT code 32020 is comparable to CPT code
38300, Drainage of lymph node abscess or lymphadenitis; simple, or CPT
code 38500, Biopsy or excision of lymph node(s); open, superficial.
Both of these CPT codes were reviewed by the RUC during the second 5-
Year Review. The RUC times for CPT code 38500 are: pre-service time of
35 minutes, intra-service time of 30 minutes and post-service time of
15 minutes, for a total time of 80 minutes, this includes one
outpatient visit resulting in a work RVU of 3.74. If the value of the
outpatient visit is removed from CPT code 38500, this results in an RVU
of 3.29. We believe CPT code 32020 compares favorably to 38500 and
propose a work RVU of 3.29 for CPT code 32020.
7. General, Colorectal and Vascular Surgery
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS--GENERAL, COLORECTAL AND VASCULAR
SURGERY'' at the beginning of your comments.]
a. General Surgery
The American College of Surgeons (ACS) submitted the following CPT
codes in Table 40 for review.
Table 40
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
38100.............................. Splenectomy; total (separate
procedure).
38101.............................. Splenectomy; partial (separate
procedure).
38115.............................. Repair of ruptured spleen
(splenorrhaphy) with or without
partial splenectomy.
43620.............................. Gastrectomy, total; with
esophagoenterostomy.
43621.............................. Gastrectomy, total; with Roux-en-Y
reconstruction.
43622.............................. Gastrectomy, total; with formation
of intestinal pouch, any type.
43632.............................. Gastrectomy, partial, distal; with
gastrojejunostomy.
43633.............................. Gastrectomy, partial, distal; with
Roux-en-Y reconstruction.
43634.............................. Gastrectomy, partial, distal; with
formation of intestinal pouch.
43820.............................. Gastrojejunostomy; without
vagotomy.
43840.............................. Gastrorrhaphy, suture of perforated
duodenal or gastric ulcer, wound,
or injury.
44120.............................. Enterectomy, resection of small
intestine; single resection and
anastomosis.
44130.............................. Enteroenterostomy, anastomosis of
intestine, with or without
cutaneous enterostomy (separate
procedure).
44143.............................. Colectomy, partial; with end
colostomy and closure of distal
segment (Hartmann type procedure).
44602.............................. Suture of small intestine
(enterorrhaphy) for perforated
ulcer, diverticulum, wound, injury
or rupture; single perforation.
44603.............................. Suture of small intestine
(enterorrhaphy) for perforated
ulcer, diverticulum, wound, injury
or rupture; multiple perforations.
44604.............................. Suture of large intestine
(colorrhaphy) for perforated
ulcer, diverticulum, wound, injury
or rupture (single or multiple
perforations); without colostomy.
44605.............................. Suture of large intestine
(colorrhaphy) for perforated
ulcer, diverticulum, wound, injury
or rupture (single or multiple
perforations); with colostomy.
47480.............................. Cholecystotomy or cholecystostomy
with exploration, drainage, or
removal of calculus (separate
procedure).
47490.............................. Percutaneous cholecystostomy.
47510.............................. Introduction of percutaneous
transhepatic catheter for biliary
drainage.
47511.............................. Introduction of percutaneous
transhepatic stent for internal
and external biliary drainage.
47525.............................. Change of percutaneous biliary
drainage catheter.
47530.............................. Revision and/or reinsertion of
transhepatic tube.
47760.............................. Anastomosis, of extrahepatic
biliary ducts and gastrointestinal
tract.
47765.............................. Anastomosis, of intrahepatic ducts
and gastrointestinal tract.
47780.............................. Anastomosis, Roux-en-Y, of
extrahepatic biliary ducts and
gastrointestinal tract.
47785.............................. Anastomosis, Roux-en-Y, of
intrahepatic biliary ducts and
gastrointestinal tract.
49000.............................. Exploratory laparotomy, exploratory
celiotomy with or without
biopsy(s) (separate procedure).
49002.............................. Reopening of recent laparotomy.
49010.............................. Exploration, retroperitoneal area
with or without biopsy(s)
(separate procedure).
------------------------------------------------------------------------
In addition, the American Society of Colon and Rectal Surgeons
(ASCRS) submitted six CPT codes for review (see Table 41).
[[Page 37227]]
Table 41
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
44150.............................. Colectomy, total, abdominal,
without proctectomy; with
ileostomy or ileoproctostomy.
44151.............................. Colectomy, total, abdominal,
without proctectomy; with
continent ileostomy.
44152.............................. Colectomy, total, abdominal,
without proctectomy; with rectal
mucosectomy, ileoanal anastomosis,
with or without loop ileostomy.
44153.............................. Colectomy, total, abdominal,
without proctectomy; with rectal
mucosectomy, ileoanal anastomosis,
creation of ileal reservoir (S or
J), with or without loop
ileostomy.
44155.............................. Colectomy, total, abdominal, with
proctectomy; with ileostomy.
44156.............................. Colectomy, total, abdominal, with
proctectomy; with continent
ileostomy.
------------------------------------------------------------------------
We submitted the CPT codes in Table 42 for review.
Table 42
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
19180.............................. Mastectomy, simple, complete.
44140.............................. Colectomy, partial; with
anastomosis.
47562.............................. Laparoscopy, surgical;
cholecystectomy.
49505.............................. Repair initial inguinal hernia, age
5 years or over; reducible.
47600.............................. Cholecystectomy.
------------------------------------------------------------------------
However, the following CPT codes were subsequently withdrawn from
the 5-Year Review: 44604, 44605, 47480, 47490, 47510, 47511, 47525 and
47530. ASCRS also withdrew CPT codes 44152 and 44153, and is referring
them to the CPT Editorial Panel.
For most codes, a standard RUC survey with over 30 responses was
used. However, the surveys for CPT code 43622 had 29 responses and CPT
code 43634 had 26 responses. Minisurveys, with over 30 responses, were
used for CPT codes 44151 and 44156. Where NSQIP data was available, the
specialty society also used an alternative methodology based on a
building-block approach that used intra-service times and length of
stay data from the NSQIP database to develop the recommendations. A
specialty society consensus panel then assigned pre-service times,
immediate post-service times, as well as IWPUT estimates, with the
number and level of office visits determined based on comparisons to
codes requiring similar physician work.
RUC Recommendations
The RUC recommended maintaining the existing RVUs for CPT codes
44140 and 49505 because the RUC believed there was a lack of compelling
evidence that the work had changed.
For those services without NSQIP data, where only survey data was
used as a basis for review, the RUC recommended the survey median for
CPT codes 38100, 38101, 38115, 43620, 43632, 43634, 44156, 47765. For
CPT code 49010, the RUC recommended use of the survey's 25th percentile
because the RUC recommended deleting one hospital visit. For CPT code
47760, the RUC recommended the 25th percentile because the RUC believed
that the 25th percentile was closer to the reference code. The RUC
recommended use of the surveyed 75th percentile (25 work RVUs) for: CPT
code 44603, which represents the suturing of multiple small intestinal
perforations, to keep the correct rank order with CPT code 44602 (22.00
recommended work RVUs) that is used for the repair of a single
perforation; CPT code 43622 because the RUC believed that the use of
the median value would create a rank order anomaly; and CPT code 44151
because the RUC believed that the survey underestimated the physician
time required for the service.
For CPT codes 47780 and 47785, the RUC used a building-block method
to arrive at a recommendation which added 4.00 work RVUs to the
recommended work RVUs for the respective base CPT codes 47760 and 47765
to account for the Roux-en-Y procedure. This resulted in recommended
RVUs that were lower than the survey median for CPT code 47780 and
higher for CPT code 47785.
For services for which NSQIP data were presented along with survey
data, the RUC recommended the use of the surveys 25th percentile for
CPT codes 19180, 47562, and 49002. The RUC used the NSQIP data to
validate the recommendation to use the surveyed median work RVUs for
CPT codes 43632, 43633, 43820, 43840, 44143, 44150, 44155 and 44602.
Other RUC recommendations used the NSQIP data to increase the work RVUs
above the survey median and, in one instance, beyond the survey's 75th
percentile. For CPT codes 44120, 44130 and 47600, the RUC believed the
physicians responding to the survey underestimated their intra-service
time. Therefore, the RUC applied what was believed to be an appropriate
IWPUT to the additional NSQIP time and added the resulting work RVUs to
the survey median.
The RUC recommended that CPT code 49000 be referred to the CPT
Editorial Panel because this code is currently used for two distinct
patient populations and needs to be separated into two codes to be
appropriately valued.
The 5-Year Review process allows specialty societies to request
that the RUC review the work RVUs of additional codes where a rank
order anomaly might have been caused by a RUC 5-Year Review
recommendation for codes in the same family. Upon reviewing the
workgroup recommendations for the partial colectomy procedures, CPT
codes 44140 and 44143, the RUC determined that other codes in the
family, CPT codes 44141, 44144, 44145, 44146 and 44147, needed to be
reviewed to avoid rank order anomalies.
The RUC considered these CPT codes at their February 2006 meeting.
The specialty society presented standard RUC surveys for all these
services. For CPT codes 44141, 44144, 44146 and 44147, the RUC
recommended the survey median. However, for CPT code 44145, the RUC
recommended to maintain the current value of 26.38
[[Page 37228]]
work RVUs because the post-operative work is slightly less than the CPT
code 44144 for which 27.00 work RVUs are recommended.
The RUC-recommended work RVUs for these CPT codes were as follows:
19180 = 14.67 work RVUs; 38100 = 18.00 work RVUs; 38101 = 18.00 work
RVUs; 38115 = 20.00 work RVUs; 43620 = 31.00 work RVUs; 43621 = 36.00
work RVUs; 43622 = 36.50 work RVUs; 43632 = 32.00 work RVUs; 43633 =
30.00 work RVUs; 43634 = 33.50 work RVUs; 43820 = 20.00 work RVUs;
43840 = 20.00 work RVUs; 44120 = 20.11 work RVUs; 44130 = 20.87 work
RVUs; 44140 = 20.97 work RVUs; 44141 = 27.00 work RVUs; 44143 = 25.00
work RVUs; 44144 = 27.00 work RVUs; 44145 = 26.38 work RVUs; 44146 =
33.00 work RVUs; 44147 = 31.00 work RVUs; 44150 = 27.50 work RVUs;
44151 = 32.00 work RVUs; 44155 = 31.50 work RVUs; 44156 = 34.50 work
RVUs; 44602 = 22.00 work RVUs; 44603 = 25.00 work RVUs; 47562 = 11.07
work RVUs; 47600 = 15.88 work RVUs; 47760 = 34.75 work RVUs; 47765 =
48.50 work RVUs; 47780 = 38.75 work RVUs; 47785 = 52.50 work RVUs;
49002 = 15.75 work RVUs; 49010 = 15.00 work RVUs; and 49505 = 7.59 work
RVUs.
CMS Proposed Valuation
We agree with the RUC-recommended work RVUs for CPT codes 19180,
38100, 38101, 38115, 43620, 43621, 43622, 43632, 43633, 43634, 43820,
43840, 44140, 44141, 44143, 44144, 44145, 44146, 44147, 44150, 44151,
44155, 44156, 44602, 44603, 47562, 47760, 47765, 47780, 47785, 49002,
49010 and 49505.
We have concerns with the RUC recommendations to use the NSQIP data
to increase the work RVUs for CPT codes 44120, 44130 and 47600 above
the median, and, for 47600 above the 75th percentile, from the survey.
While we support the use of such a database as validation for survey
results, we believe that the application of the NSQIP IWPUT to the 25-
minute difference in intra-time between the survey and NSQIP is
questionable. First, it is still not clear whether the NSQIP data is
truly representative. Second, the IWPUT applied to the additional 25
minutes is higher than the IWPUT for the rest of the intra-time. Third,
such a methodology assumes, without evidence, that there is a linear
relationship between the survey respondents' estimate of time and
estimate of work RVUs; however, even if the survey time estimates had
matched the NSQIP data, it is not clear whether or by how much the
respondents would have increased their work value estimate. Fourth,
until we have available valid and representative data such as the NSQIP
for all procedures, there is the risk that applying the data randomly
could distort the relativity between services. Therefore, we are
proposing to use the median survey values of 18.00, 20.00 and 14.00 as
the work RVUs for CPT codes 44120, 44130 and 47600, respectively.
b. Colon and Rectal Surgery
The ASCRS submitted several colorectal surgery CPT codes (see Table
43).
Table 43
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
45020.............................. Incision and drainage of deep
supralevator, pelvirectal, or
retrorectal abscess.
45300.............................. Proctosigmoidoscopy, rigid;
diagnostic, with or without
collection of specimen(s) by
brushing or washing (separate
procedure).
45303.............................. Proctosigmoidoscopy, rigid; with
dilation (e.g., balloon, guide
wire, bougie).
45305.............................. Proctosigmoidoscopy, rigid; with
biopsy, single or multiple.
45307.............................. Proctosigmoidoscopy, rigid; with
removal of foreign body.
45308.............................. Proctosigmoidoscopy, rigid; with
removal of single tumor, polyp, or
other lesion by hot biopsy forceps
or bipolar cautery.
45309.............................. Proctosigmoidoscopy, rigid; with
removal of single tumor, polyp, or
other lesion by snare technique.
45315.............................. Proctosigmoidoscopy, rigid; with
removal of multiple tumors,
polyps, or other lesions by hot
biopsy forceps, bipolar cautery or
snare technique.
45317.............................. Proctosigmoidoscopy, rigid; with
control of bleeding (e.g.,
injection, bipolar cautery,
unipolar cautery, laser, heater
probe, stapler, plasma
coagulator).
45320.............................. Proctosigmoidoscopy, rigid; with
ablation of tumor(s), polyp(s), or
other lesion(s) not amenable to
removal by hot biopsy forceps,
bipolar cautery or snare technique
(e.g., laser).
45321.............................. Proctosigmoidoscopy, rigid; with
decompression of volvulus.
45327.............................. Proctosigmoidoscopy, rigid; with
transendoscopic stent placement
(includes predilation).
46040.............................. Incision and drainage of
ischiorectal and/or perirectal
abscess (separate procedure).
46045.............................. Incision and drainage of
intramural, intramuscular, or
submucosal abscess, transanal,
under anesthesia.
46060.............................. Incision and drainage of
ischiorectal or intramural
abscess, with fistulectomy or
fistulotomy, submuscular, with or
without placement of seton.
46270.............................. Surgical treatment of anal fistula
(fistulectomy/fistulotomy);
subcutaneous.
46275.............................. Surgical treatment of anal fistula
(fistulectomy/fistulotomy);
submuscular.
46280.............................. Surgical treatment of anal fistula
(fistulectomy/fistulotomy);
complex or multiple, with or
without placement of seton.
46285.............................. Surgical treatment of anal fistula
(fistulectomy/fistulotomy); second
stage.
46600.............................. Anoscopy; diagnostic, with or
without collection of specimen(s)
by brushing or washing (separate
procedure).
46604.............................. Anoscopy; with dilation (e.g.,
balloon, guide wire, bougie).
46606.............................. Anoscopy; with biopsy, single or
multiple.
46608.............................. Anoscopy; with removal of foreign
body.
46610.............................. Anoscopy; with removal of single
tumor, polyp, or other lesion by
hot biopsy forceps or bipolar
cautery.
46611.............................. Anoscopy; with removal of single
tumor, polyp, or other lesion by
snare technique.
46612.............................. Anoscopy; with removal of multiple
tumors, polyps, or other lesions
by hot biopsy forceps, bipolar
cautery or snare technique.
46614.............................. Anoscopy; with control of bleeding
(e.g., injection, bipolar cautery,
unipolar cautery, laser, heater
probe, stapler, plasma
coagulator).
46615.............................. Anoscopy; with ablation of
tumor(s), polyp(s), or other
lesion(s) not amenable to removal
by hot biopsy forceps, bipolar
cautery or snare technique.
46760.............................. Sphincteroplasty, anal, for
incontinence, adult; muscle
transplant.
46761.............................. Sphincteroplasty, anal, for
incontinence, adult; levator
muscle imbrication (Park posterior
anal repair).
46762.............................. Sphincteroplasty, anal, for
incontinence, adult; implantation
artificial sphincter.
------------------------------------------------------------------------
[[Page 37229]]
ASCRS subsequently withdrew CPT codes 46760, 46761 and 46762 from
the 5-Year Review.
For most codes, a standard RUC survey with over 30 responses was
used. A minisurvey was used for a few codes.
RUC Recommendations
The RUC agreed with the specialty society's recommendations to
maintain the current work RVUs for CPT codes 46040, 46060 and 46280
because the survey data supported the existing work associated with the
code.
The RUC recommended the increased work RVUs at the surveys' median
work values, as requested by the specialty society, for CPT codes
45020, 46045, 46270, 46275 and 46285.
For the proctoscopy-anoscopy family of codes, the RUC agreed that
the surveyed median work RVUs, and often even the 25th percentile, were
inconsistent with the reference code. Therefore, the RUC did not
reference the surveyed RVUs in arriving at the recommendations. Rather,
the RUC used the surveyed times for each service and applied what the
workgroup considered an appropriate IWPUT to these times to arrive at
the recommended work RVUs for this family.
The specific RUC work RVU recommendations for these colon and
rectal surgery CPT codes were as follows: 45020 = 7.75 work RVUs; 45300
= 0.91 work RVUs; 45303 = 2.22 work RVUs; 45305 = 2.01 work RVUs; 45307
= 2.22 work RVUs; 45308 = 2.01 work RVUs; 45309 = 2.22 work RVUs; 45315
= 2.22 work RVUs; 45317 = 1.08 work RVUs; 45320 = 2.43 work RVUs; 45321
= 2.76 work RVUs; 45327 = 3.63 work RVUs; 46040 = 4.95 work RVUs; 46045
= 5.50 work RVUs; 46060 = 5.68 work RVUs; 46270 = 4.50 work RVUs; 46275
= 5.00 work RVUs; 46280 = 5.97 work RVUs; 46285 = 5.00 work RVUs; 46600
= 0.49 work RVUs; 46604 = 1.08 work RVUs; 46606 = 1.76 work RVUs; 46608
= 1.95 work RVUs; 46610 = 1.95 work RVUs; 46611 = 1.08 work RVUs; 46612
= 2.14 work RVUs; 46614 = 1.08 work RVUs; and 46615 = 1.18 work RVUs.
CMS Proposed Valuation
We agree with the RUC-recommended work RVUs for CPT codes 45020,
46040, 46045, 46060, 46270, 46275, 46280, and 46285.
We are proposing not to accept the RUC recommendations for all the
presented codes in the proctoscopy-anoscopy family. We are proposing to
maintain the current work RVUs for CPT codes 45300, 45303, 45305,
45307, 45308, 45309, 45315, 45317, 45320, 45321, 45327, 46600, 46604,
46606, 46608, 46610, 46611, 46612, 46614 and 46615.
We believe that the method used by the RUC to obtain work values
for these services was flawed. The calculation of the recommended work
RVUs depended solely on applying a workgroup-derived IWPUT to the
surveyed physician time from surveys that were considered otherwise
unusable. We do not believe that the use of IWPUT, in the absence of
other supporting data, has been previously accepted by the RUC. We
believe the RUC has established rules that state that IWPUT cannot be
the sole rationale for valuation and it appears that this workgroup
might not have adhered to that standard. We believe that this use of
IWPUT differs from that used by workgroup one, as described above.
There were acceptable surveys that were used as anchors to create the
correct rank order for the dermatology codes without adequate surveys.
In addition, for the dermatology codes, the calculation was generally
used to validate the current or lower work RVUs for the services, while
for these scope codes, the calculation was not used to validate but to
support significant increases for many of the services. However, if the
specialty society wishes to resurvey these codes and the RUC submits
work RVU recommendations to CMS, we would certainly be willing to
consider them.
c. Vascular Surgery
The Society for Vascular Surgery (SVS) submitted the CPT codes in
Table 44 for review. However, the specialty society subsequently
withdrew CPT codes 27603, 35612 and 35642 from review.
Table 44
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
27603.............................. Incision and drainage, leg or
ankle; deep abscess or hematoma.
27880.............................. Amputation, leg, through tibia and
fibula.
28805.............................. Amputation, foot; transmetatarsal.
33877.............................. Repair of thoracoabdominal aortic
aneurysm with graft, with or
without cardiopulmonary bypass.
34001.............................. Embolectomy or thrombectomy, with
or without catheter; carotid,
subclavian or innominate artery,
by neck incision.
34201.............................. Embolectomy or thrombectomy, with
or without catheter;
femoropopliteal, aortoiliac
artery, by leg incision.
34471.............................. Thrombectomy, direct or with
catheter; subclavian vein, by neck
incision.
35081.............................. Direct repair of aneurysm,
pseudoaneurysm, or excision
(partial or total) and graft
insertion, with or without patch
graft; for aneurysm,
pseudoaneurysm, and associated
occlusive disease, abdominal
aorta.
35102.............................. Direct repair of aneurysm,
pseudoaneurysm, or excision
(partial or total) and graft
insertion, with or without patch
graft; for aneurysm,
pseudoaneurysm, and associated
occlusive disease, abdominal aorta
involving iliac vessels (common,
hypogastric, external).
35216.............................. Repair blood vessel, direct;
intrathoracic, without bypass.
35381.............................. Thromboendarterectomy, with or
without patch graft; femoral and/
or popliteal, and/or
tibioperoneal.
35501.............................. Bypass graft, with vein; carotid.
35506.............................. Bypass graft, with vein; carotid-
subclavian.
35507.............................. Bypass graft, with vein; subclavian-
carotid.
35508.............................. Bypass graft, with vein; carotid-
vertebral.
35509.............................. Bypass graft, with vein; carotid-
carotid.
35515.............................. Bypass graft, with vein; subclavian-
vertebral.
35516.............................. Bypass graft, with vein; subclavian-
axillary.
35541............................. Bypass graft, with vein; aortoiliac
or bi-iliac.
35546.............................. Bypass graft, with vein;
aortofemoral or bifemoral.
35556.............................. Bypass graft, with vein; femoral-
popliteal.
35566.............................. Bypass graft, with vein; femoral-
anterior tibial, posterior tibial,
peroneal artery or other distal
vessels.
35583.............................. In-situ vein bypass; femoral-
popliteal.
35585.............................. In-situ vein bypass; femoral-
anterior tibial, posterior
tibial,or peroneal artery.
35601.............................. Bypass graft, with other than vein;
carotid.
35606.............................. Bypass graft, with other than vein;
carotid-subclavian.
[[Page 37230]]
35612.............................. Bypass graft, with other than vein;
subclavian-subclavian.
35616.............................. Bypass graft, with other than vein;
subclavian-axillary.
35641.............................. Bypass graft, with other than vein;
aortoiliac or bi-iliac.
35642.............................. Bypass graft, with other than vein;
carotid-vertebral.
37720.............................. Ligation and division and complete
stripping of long or short
saphenous veins.
60600.............................. Excision of carotid body tumor;
without excision of carotid
artery.
60605.............................. Excision of carotid body tumor;
with excision of carotid artery.
------------------------------------------------------------------------
For all codes, a standard RUC survey was used. All but the
following CPT codes had 30 or more responses: 34471 (28 responses),
35508 (23 responses), 35515 (18 responses), 35516 (29 responses), 35616
(29 responses), 60600 (19 responses). The specialty society also used
the intra-service times and length of stay data from the NSQIP database
to develop some of its recommendations. A specialty society consensus
panel then assigned pre-service times, and immediate post-service
times, as well as IWPUT estimates.
RUC Recommendations
The RUC agreed with the specialty society that the following CPT
codes cannot undergo the RUC evaluation process before having their
descriptors revised and recommended referring these CPT codes to the
CPT Editorial panel: 35381, 35501, 35507, 35509, 35541, 35546, 35601,
35641 and 37720. (Note that CPT code 37720 was subsequently deleted by
CPT for CY 2006.) For the remaining codes, the RUC reviewed both the
survey data and the NSQIP data, where provided, for each procedure. In
many instances, where the NSQIP time and length of stay data were
available, the RUC believed that the physicians responding to the
survey underestimated their intra-service time and that the NSQIP data
more accurately reflected the actual intra-service times for these
procedures.
The RUC accepted the specialty society's requested increase in work
RVUs for 12 CPT codes, agreeing with the specialty society that these
procedures were undervalued due to compelling evidence such as changes
in length of stay, changes in patient populations, and incorrect
assumptions made in the previous valuation of the service. For CPT
codes 27880, 28805, 34001, 34471, 35506, 35508, 35515, 35516, 35606,
60600 and 60605, the RUC-recommended work RVUs were at the survey
median or lower. However, for CPT code 33877, the RUC accepted a work
value greater than the survey's 75th percentile that was derived from a
building-block approach using the NSQIP data for the service. The RUC
increased the work RVUs for nine codes. For eight of the codes, the
increases were at levels below those requested by the specialty
society, and for one code the increase was slightly higher than the
requested work RVUs. For CPT codes 35081, 35216, 35583 and 35616, the
recommended increase was no higher than the surveyed median work RVUs.
For CPT codes 34201, 35102, 35556, 35566, and 35585, the RUC accepted
work values greater than the survey's median percentile that were
derived from a building-block approach using the NSQIP data for the
service.
The specific RUC-recommended work RVUs for these CPT codes are as
follows: 27880 = 13.75 work RVUs; 28805 = 11.25 work RVUs; 33877 =
64.04 work RVUs; 34001 = 16.25 work RVUs; 34201 = 18.31 work RVUs;
34471 = 20.00 work RVUs; 35081 = 31.00 work RVUs; 35102 = 36.28 work
RVUs; 35216 = 34.00 work RVUs; 35506 = 23.75 work RVUs; 35508 = 25.00
work RVUs; 35515 = 25.00 work RVUs; 35516 = 23.00 work RVUs; 35556 =
27.25 work RVUs; 35566 = 32.00 work RVUs; 35583 = 26.00 work RVUs;
35585 = 32.00 work RVUs; 35606 = 21.00 work RVUs; 35616 = 21.00 work
RVUs; 60600 = 24.00 work RVUs; and 60605 = 30.50 work RVUs.
CMS Proposed Valuation
We accept the RUC-recommended work RVUs for CPT codes 27880, 28805,
34001, 34471, 35216, 35506, 35508, 35515, 35516, 35606, 60600, 60605,
35081, 35583, and 35616.
We disagree with the RUC recommendations for CPT codes 33877,
34201, 35102, 35556, 35566, and 35585. For these services, the RUC used
the NSQIP time data to increase the work values above the survey
median, and even for above several codes the 75th percentile. For the
reasons discussed above, we reject such a use of the NSQIP data at this
time. Therefore, we are proposing to use the survey median work RVUs
for these CPT codes: 33877 = 53.00 work RVUs; 34201 = 17.00 work RVUs;
35102 = 34.00 work RVUs; 35556 = 25.00 work RVUs; 35566 = 30.00 work
RVUs; and 35585 = 30.00 work RVUs.
8. Otolaryngology and Ophthalmology
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS-OTOLARYNGOLOGY AND OPTHALMOLOGY''
at the beginning of your comments.]
a. Otolaryngology Procedures
The American Academy of Otolaryngology--Head and Neck Surgery (AAO-
HNS) submitted the CPT codes in Table 45 for review.
Table 45
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
31225.............................. Maxillectomy; without orbital
extenteration.
31230.............................. Maxillectomy; with orbital
exenteration (en bloc).
31360.............................. Laryngectomy; total, without
radical neck dissection.
31365.............................. Laryngectomy; total, with radical
neck dissection.
31367.............................. Laryngectomy; subtotal
supraglottic, without radical neck
dissection.
31368.............................. Laryngectomy; subtotal
supraglottic, with radical neck
dissection.
31370.............................. Partial laryngectomy
(hemilaryngectomy); horizontal.
31375.............................. Partial laryngectomy
(hemilaryngectomy);
laterovertical.
31380.............................. Partial laryngectomy
(hemilaryngectomy);
anterovertical.
31382.............................. Partial laryngectomy
(hemilaryngectomy); antero-latero-
vertical.
[[Page 37231]]
31390.............................. Pharyngolaryngectomy, with radical
neck dissection; without
reconstruction.
31395.............................. Pharyngolaryngectomy, with radical
neck dissection; with
reconstruction.
38700.............................. Suprahyoid lymphadenectomy.
38720.............................. Cervical lymphadenectomy
(complete).
38724.............................. Cervical lymphadenectomy (modified
radical neck dissection).
41120.............................. Glossectomy; less than one-half
tongue.
41130.............................. Glossectomy; hemiglossectomy.
41135.............................. Glossectomy; partial, with
unilateral radical neck
dissection.
41140.............................. Glossectomy; complete or total,
with or without tracheostomy,
without radical neck dissection.
41145.............................. Glossectomy; complete or total,
with or without tracheostomy, with
unilateral radical neck
dissection.
41150.............................. Glossectomy; composite procedure
with resection floor of mouth and
mandibular resection, without
radical neck dissection.
41153.............................. Glossectomy; composite procedure
with resection floor of mouth,
with suprahyoid neck dissection.
41155.............................. Glossectomy; composite procedure
with resection floor of mouth,
mandibular resection, and radical
neck dissection (Commando type).
42120.............................. Resection of palate or extensive
resection of lesion.
42842.............................. Radical resection of tonsil,
tonsillar pillars, and/or
retromolar trigone; without
closure.
42844.............................. Radical resection of tonsil,
tonsillar pillars, and/or
retromolar trigone; closure with
local flap (e.g., tongue, buccal).
42845.............................. Radical resection of tonsil,
tonsillar pillars, and/or
retromolar trigone; closure with
other flap.
42890.............................. Limited pharyngectomy.
42892.............................. Resection of lateral pharyngeal
wall or pyriform sinus, direct
closure by advancement of lateral
and posterior pharyngeal walls.
42894.............................. Resection of pharyngeal wall
requiring closure with
myocutaneous flap.
------------------------------------------------------------------------
We initially requested that the RUC review five CPT codes but then
withdrew CPT code 31255 from the 5-Year Review (see Table 46).
Table 46
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
30520.............................. Septoplasty or submucous resection,
with or without cartilage scoring,
contouring replacement with graft.
31255.............................. Nasal/sinus endoscopy, surgical;
with ethmoidectomy, total
(anterior and posterior).
31575.............................. Laryngoscopy, flexible fiberoptic;
diagnostic.
31579.............................. Laryngoscopy, flexible or rigid
fiberoptic, with stroboscopy.
41100.............................. Biopsy of tongue; anterior two-
thirds.
69210.............................. Removal impacted cerumen (separate
procedure), one or both ears.
------------------------------------------------------------------------
RUC Recommendations
For one CPT code 42120, palate resection procedure, the RUC, based
on the data presented by the specialty society, agreed that there was
increased work and intensity involved in comparison to other codes with
similar intensity. The RUC believed the survey results reflected the
complexity of the patient, physician time and work necessary in
performing this procedure, and recommended work RVUs of 11.00 for CPT
code 42120.
The specialty society presented data on two maxillectomy
procedures, CPT codes 31225 and 31230, which the RUC also viewed as
undervalued. The RUC believed that the re-evaluation of these two codes
corrects rank order anomalies and accounts for the appropriate
intensity for each procedure. The RUC recommended work RVUs of 24.00
for CPT code 31225 and 28.00 for CPT code 31230.
For three lymphadendectomy procedures, CPT codes 38700, 38720, and
38724, the specialty society presented data with the rationale that the
previous valuation was flawed because the procedures were not evaluated
by otolaryngologists. The RUC believed that the survey results
reflected the appropriate complexity of the patient, physician time and
work necessary in performing the procedure, and justified an increase
in physician work. The RUC-recommended work RVUs for these CPT codes
are as follows: 38700 = 12.00 work RVUs; 38720 = 20.00 work RVUs; and
38724 = 22.00 work RVUs.
The specialty society presented survey data on three pharyngectomy
procedures, CPT codes 42890, 42892, and 42894, which had never been
reviewed by the RUC. The RUC agreed that there was a change in the
patient population and that the increased intensity involved in these
procedures was comparable to other codes with similar intensity. The
RUC recommended the increase demonstrated by the survey median which
was 17.00 work RVUs for CPT code 42890, 23.09 work RVUs for CPT code
42892, and 30.00 work RVUs for CPT code 42894.
The specialty society presented survey data on three tonsillectomy
procedures, CPT codes 42842, 42844, and 42845, which the RUC agreed
were undervalued due to a previous flawed methodology. The RUC believed
that the survey results reflected the appropriate physician work and
time necessary in performing this procedure and recommended the
following work RVUs for these CPT codes: 42842 = 11.00 work RVUs; 42844
= 16.10 work RVUs; and 42845 = 32.00 work RVUs.
For the partial glossectomy procedures, CPT codes 41120, 41130, and
41135, the RUC believed that there was not compelling evidence to
increase the work for CPT code 41120, and, therefore, recommended
maintaining the current value for this service. The RUC also agreed
that increasing the values for the two remaining procedures would
correct the existing rank order anomalies and that these increases were
[[Page 37232]]
justified by survey results. The recommendation for the work RVUs for
these CPT codes is as follows: 41120 = 9.76 work RVUs; 41130 = 14.00
work RVUs; and 41135 = 27.00 work RVUs.
For complete glossectomy procedures, CPT codes 41140 and 41145, the
specialty society presented survey data on these procedures and
suggested decreasing the work RVU of CPT code 41140. The RUC believed
that the survey results did not justify decreasing the work RVUs for
this service, particularly because over half of the survey respondents
indicated that the work of performing CPT code 41140 has not changed in
the past 5 years. Therefore, the RUC recommended maintaining the value
for this code. The RUC believed that the flawed methodology previously
used for valuing CPT code 41145 caused this procedure to be misvalued
and that an increase in work was validated by the survey median
results. The RUC recommended the following work RVUs for these CPT
codes: 41140 = 25.46 work RVUs; and 41145 = 34.00 work RVUs.
For the composite glossectomy procedures, CPT codes 41150, 41153,
and 41155, the specialty society presented survey data on each of these
procedures, noting that the current work RVUs for each of these
services create a rank order anomaly. The RUC agreed that increasing
the RVUs would correct these rank order anomalies and that these
increases were justified by the survey results. The RUC-recommended
work RVUs for these CPT codes are as follows: 41150 = 26.50 work RVUs;
41153 = 34.00 work RVUs; and 41155 = 40.00 work RVUs.
For the laryngopharyngectomy procedures, CPT codes 31360, 31365,
31390 and 31395, the specialty society presented as compelling evidence
the rationale that the current work RVUs create rank order anomalies,
and that there also has been a change in the patient population. The
RUC agreed that increasing the RVUs of these procedures by accepting
the 75th percentile of survey results corrected the specific rank order
anomalies and also accounted for the change in the patient population.
The RUC-recommended work RVUs for these CPT codes are as follows: 31360
= 28.00 work RVUs; 31365 = 37.00 work RVUs; 31390 = 40.00 work RVUs;
and 31395 = 44.00 work RVUs.
For the laryngectomy procedures, CPT codes 31367, 31368, 31370,
31375, 31380 and 31382, the specialty society presented survey data
with the rationale that the current work values are based on a flawed
methodology that creates rank order anomalies, and that there also has
been a change in patient population. The RUC agreed with the specialty
society and recommended increasing the work RVUs for these services to
maintain rank order between the codes in the family and to establish
the correct intensity of the procedure based on the change in patient
population. The RUC-recommended work RVUs for these CPT codes are:
31367 = 27.36 work RVUs; 31368 = 36.00 work RVUs; 31370 = 25.00 work
RVUs; 31375 = 25.00 work RVUs; 31380 = 25.00 work RVUs; and 31382 =
28.00 work RVUs.
For CPT code 30520, based on the increase in physician time in the
current survey data, the RUC believed that the service was misvalued
and that there was additional work involved which was not previously
captured. Using the building-block methodology, the RUC recommended a
work RVU of 6.27 for CPT code 30520.
For CPT codes 31575 and 31579, the RUC agreed with the specialty
society that the surveys validate the current values. The RUC also
believed that the survey validated the current work value for CPT code
41100, particularly because 98 percent of survey respondents indicated
that the work in performing this service has not changed in the past 5
years. The RUC recommended maintaining the original work values of 1.10
work RVUs for CPT code 31575, 2.26 work RVUs for CPT code 31579, and
1.63 work RVUs for CPT code 41100.
The specialty society provided survey data for CPT code 69210 using
the rationale that the patient population had become more complex. The
RUC did not agree with the specialty society that the patient
population had changed because 94 percent of the survey respondents
indicated that the work in performing this service has not changed in
the past 5 years. The RUC recommended maintaining the current work
value of 0.61 for this service.
CMS Proposed Valuation
We are in agreement with the RUC-recommended work RVUs for the
following otolaryngology CPT codes: 38700, 38720, 38724, 41120, 41130,
41135, 41140, 41145, 42120, 42890, 42892, and 42894.
For the tonsillectomy procedures, CPT codes 42842, 42844, and
42845, the number of hospital days decreased by at least two days
(including critical care visits for one code), but the outpatient post-
operative visits increased by one. The median values for intra-service
times were accepted by the RUC for these services, which is an
indication that a value other than the 75th percentile for work also
may be appropriate. CPT codes 42842 and 42844 were valued at the median
work RVU obtained from the surveys. However, CPT code 42845 was valued
by the RUC at the 75th percentile for work. Therefore, we are accepting
the median recommended work values for CPT codes 42842 of 11.00 work
RVUs and 42844 of 16.10 work RVUs and, consistent with use of the
median, proposing work RVUs for CPT code 42845 of 29.00.
For the composite glossectomy procedures, CPT codes 41150, 41153,
and 41155, the number of hospital days decreased by at least 2 days
(including, in some instances, critical care visits). CPT codes 41153
and 41155 were valued by the RUC at the 75th percentile for work, but
CPT code 41150 was valued based on the median work value. The median
values for intra-service times were accepted by the RUC for these
services, which is an indication that a value other than the 75th
percentile for work also may be appropriate. Therefore, we are
accepting the RUC-recommended work RVUs of 26.50 for CPT code 41150
which were based on the median work value, and consistent with use of
the median proposing work RVUs of 30.00 for CPT code 41153 and 36.00
for CPT code 41155.
For the laryngopharyngectomy procedures, CPT codes 31360, 31365,
31367, 31368, 31370, 31375, 31380, 31382, 31390 and 31395, the number
of hospital days decreased by at least two days and the post-operative
outpatient visits increased by one day. However, in one instance the
number of outpatient visits decreased (CPT code 31395). The median
values for intra-service times were accepted by the RUC for these
services, which is an indication that a value other than the 75th
percentile for work also may be appropriate. Therefore, we are
proposing using median values for these services resulting in the
following work RVUs for these CPT codes: 31360 = 24.00 work RVUs; 31365
= 31.50 work RVUs; 31367 = 24.00 work RVUs; 31368 = 30.50 work RVUs;
31370 = 24.00 work RVUs; 31375 = 22.50 work RVUs; 31380 = 22.00 work
RVUs; 31382 = 25.00 work RVUs; 31390 = 35.00 work RVUs; and 31395 =
39.50 work RVUs.
For CPT codes 30520, 31575, 31579, 41100 and 69210, we are in
agreement with the RUC-recommended work RVUs for these services, except
for CPT code 41100. The RUC recommended maintaining the current work
RVUs of 1.63 for this service, which is even greater than the 75th
percentile for work, which is what the specialty
[[Page 37233]]
society had recommended. We believe the more appropriate work RVUs for
this service is represented by the median, which is 1.37, and,
therefore, we are recommending 1.37 work RVUs for CPT code 41100.
We would note that although we accepted the RUC's recommendation of
a work RVU of 0.61 for CPT code 69210, we are concerned with this
valuation for the use of this code for routine removal of ear wax
during a physical examination of a patient. This code is listed with a
``separate procedure'' designation in the CPT code book, meaning that
it is billed most properly when it is the only service provided for a
particular date of service. However, Medicare data used for evaluation
of codes in the current 5-Year Review indicate that CPT code 69210 was
billed with an E/M service 63 percent of the time. It is our
understanding that CPT code 69210 is to be used when there is a
substantial amount of cerumen in the external ear canal that is very
difficult to remove and that impairs the patient's auditory function.
We will continue to monitor the use of this code for the appropriate
circumstances.
b. Ophthalmology Services
The American Academy of Ophthalmology (AAO), the American
Optometric Association (AOA) and the American Society of Cataract and
Refractive Surgery submitted 15 codes for the 5-Year Review (see Table
47). However, the specialty societies subsequently withdrew five of
these codes (CPT codes 65420, 65900, 67917, 67924 and 68750) from the
5-Year Review.
Table 47
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
65420.............................. Excision or transposition of
pterygium; without graft.
65426.............................. Excision or transposition of
pterygium; with graft.
65850.............................. Trabeculotomy ab externo.
65900.............................. Removal of epithelial downgrowth,
anterior chamber of eye.
67414.............................. Orbitotomy without bone flap
(frontal or transconjunctival
approach); with removal of bone
for decompression.
67445.............................. Orbitotomy with bone flap or
window, lateral approach (e.g.,
Kroenlein); with removal of bone
for decompression.
67500.............................. Retrobulbar injection; medication
(separate procedure, does not
include supply of medication).
67505.............................. Retrobulbar injection; alcohol.
67515.............................. Injection of medication or other
substance into Tenon's capsule.
67904.............................. Repair of blepharoptosis; (tarso)
levator resection or advancement,
external approach.
67911.............................. Correction of lid retraction.
67917.............................. Repair of ectropion; extensive
(e.g., tarsal strip operations).
67924.............................. Repair of entropion; extensive
(e.g., tarsal strip or
capsulopalpebral fascia repairs
operation).
67966.............................. Excision and repair of eyelid,
involving lid margin, tarsus,
conjunctiva, canthus, or full
thickness, may include preparation
for skin graft or pedicle flap
with adjacent tissue transfer or
rearrangement; over one-fourth of
lid margin.
68750.............................. Conjunctivorhinostomy
(fistulization of conjunctiva to
nasal cavity); with insertion of
tube or stent .
------------------------------------------------------------------------
We submitted the following ophthalmology CPT codes for review (see
Table 48).
Table 48
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
66761.............................. Iridotomy/iridectomy by laser
surgery (e.g., for glaucoma) (one
or more sessions).
66821.............................. Discission of secondary membranous
cataract (opacified posterior lens
capsule and/or anterior hyaloid);
laser surgery (e.g., YAG laser)
(one or more stages).
66984.............................. Extracapsular cataract removal with
insertion of intraocular lens
prosthesis (one stage procedure),
manual or mechanical technique
(e.g., irrigation and aspiration
or phacoemulsification).
67038.............................. Vitrectomy, mechanical, pars plana
approach; with epiretinal membrane
stripping.
67221.............................. Destruction of localized lesion of
choroid (e.g., choroidal
neovascularization); photodynamic
therapy (includes intravenous
infusion).
67228.............................. Destruction of extensive or
progressive retinopathy (e.g.,
diabetic retinopathy), one or more
sessions; photocoagulation (laser
or xenon arc).
67820.............................. Correction of trichiasis;
epilation, by forceps only.
67840.............................. Excision of lesion of eyelid
(except chalazion) without closure
or with simple direct closure.
68840.............................. Probing of lacrimal canaliculi,
with or without irrigation.
76519.............................. Ophthalmic biometry by ultrasound
echography, A-scan; with
intraocular lens power
calculation.
92083.............................. Visual field examination,
unilateral or bilateral, with
interpretation and report;
extended examination (e.g.,
Goldmann visual fields with at
least 3 isopters plotted and
static determination within the
central 30[deg], or quantitative,
automated threshold perimetry,
Octopus program G-1, 32 or 42,
Humphrey visual field analyzer
full threshold programs 30-2, 24-2
or 30/60-2.
92226.............................. Ophthalmoscopy, extended, with
retinal drawing (e.g., for retinal
detachment, melanoma), with
interpretation and report;
subsequent.
92235.............................. Fluorescein angiography (includes
multiframe imaging) with
interpretation and report.
92250.............................. Fundus photography with
interpretation and report.
------------------------------------------------------------------------
[[Page 37234]]
RUC Recommendations
The RUC questioned the survey results for CPT codes 67038 and 67228
and indicated that the survey data may be flawed because respondents
may have based their answers on a different number of membranes
stripped or sessions conducted. The RUC recommended that these two CPT
codes be referred to the CPT Editorial Panel for clarification.
Based on a review of the survey data, the RUC agreed with the
specialty society that the survey results demonstrated that the work
had not changed and, thus, that the current work RVUs should be
retained for the following CPT codes: 66761 = 4.06 work RVUs; 67840 =
2.04 work RVUs; 68840 = 1.25 work RVUs; 76519 = 0.54 work RVUs; 92226 =
0.33 work RVUs; 92235 = 0.81 work RVUs; and 92250 = 0.44 work RVUs. In
addition, the RUC recommended retaining the work RVU of 0.50 for CPT
code 92083 because the specialty society had not presented compelling
evidence that the physician work had changed.
For CPT codes 67221, 67820, and 66984, the RUC recommended
reductions in the work RVUs. The RUC used a building-block approach
based on the work RVU of 3.24 for the reference CPT code 67141,
Prophylaxis of retinal detachment (e.g., retinal break, lattice
degeneration) without drainage, one or more sessions; cryotherapy,
diathermy, and the work RVUs of 0.21 for the infusion code G0347, which
contain comparable work. The RUC recommended work RVUs of 3.45 for CPT
code 67221.
The RUC supported the specialty society's recommendation to
decrease the work value for CPT code 67820 based on evidence that the
previous Harvard survey data was flawed. The RUC agreed with assigning
work RVUs of 0.71 to CPT code 67820 based on a comparison/crosswalk to
the key reference service, CPT code 65205, Removal of foreign body,
external eye; conjunctival superficial, which has work RVUs of 0.71.
For CPT code 66984, the RUC did not agree with the specialty
society recommendation that the current work RVU of 10.21 should be
maintained, because changes in technology and technique in the last 10
years have led to increased efficiencies. The RUC concluded that these
efficiencies resulted in a lower overall time for the procedure. The
RUC used the previous survey pre-service time of 44 minutes and
subtracted the current survey pre-service time of 25 minutes for a
difference of 19 minutes. These 19 minutes were then multiplied by an
IWPUT of 0.0224, resulting in an RVU of 0.43, which was subtracted from
the current value. The RUC agreed that although the intra-service
physician time has decreased from the historical 50 minutes to the
current survey time of 30 minutes as indicated by the survey
respondents, the decrease in time reflects a decrease of only low
intensity work (that is, suturing) and no further decrease in work RVUs
was recommended. Therefore, the RUC recommended work RVUs of 9.78 for
CPT code 66984.
The RUC agreed with the specialty society that there was compelling
evidence to support the increases for CPT codes 67414, 67445, 67500,
67515, 67904, 67911, and 67966, either because the current work RVUs
caused rank order anomalies, the previous Harvard survey data was
misvalued when compared to codes with similar values, or there was a
change in the technique of performing the procedures (specifically for
CPT codes 67911 and 67966, in which skin-grafting is bundled into these
codes). However, for two CPT codes, 65426 and 65850, while the RUC
recognized that there was compelling evidence to support increases, the
RUC did not agree with the specific increases recommended by the
specialty society.
For CPT code 65426, the RUC believed that evidence suggested a
change in technique for this procedure, and believed that a value close
to the survey's 25th percentile was justified by using a building-block
approach. For CPT code 65850, the RUC agreed that there is a rank order
anomaly between CPT codes 65850 and 66170, Fistualization of sclera for
glaucoma; trabeculectomy ab externo in absence of previous surgery, as
well as a change in the patient population. The RUC believed an
increase in value was justified by using a building-block approach. The
RUC recommended 5.85 work RVUs for CPT code 65426 and 11.14 work RVUs
for CPT code 65850.
For CPT code 66821, the RUC agreed that the intensity of this
procedure was misvalued and that an increase in the relative value
would be appropriate. The RUC disagreed with our previous intensity
crosswalk to CPT code 66984, Extracapsular cataract removal with
insertion of intraocular lens prosthesis (one stage procedure), manual
or mechanical technique (e.g., irrigation and aspiration or
phacoemulsification), specified in the Five-Year Review of Work
Relative Value Units Under the Physician Fee Schedule proposed notice
(May 3, 1996; 61 FR 20027). The RUC believed that the previous survey
from 1995 should stand on its own as an acceptable survey due to the
inappropriate selection by HCFA in 1995 of intensity for this code. The
RUC-recommended work RVU for this service is 2.78, the same value
recommended by the RUC in 1995.
CMS Proposed Valuation
We are in agreement with the RUC recommended work values for these
ophthalmology services.
c. Additional Codes
The American Speech-Language-Hearing Association (ASHA) submitted
the following speech and audiology CPT codes (see Table 49) but
subsequently withdrew them from the 5-Year Review.
Table 49
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
92506.............................. Evaluation of speech, language,
voice, communication, and/or
auditory processing.
92507.............................. Treatment of speech, language,
voice, communication, and/or
auditory processing disorder;
individual.
92508.............................. Treatment of speech, language,
voice, communication, and/or
auditory processing disorder;
group, two or more individuals.
92510.............................. Aural rehabilitation following
cochlear implant (includes
evaluation of aural rehabilitation
status and hearing, therapeutic
services) with or without speech
processor programming
92516.............................. Facial nerve function studies
(e.g., electroneuronography).
92520.............................. Laryngeal function studies (ie,
aerodynamic testing and acoustic
testing).
92526.............................. Treatment of swallowing dysfunction
and/or oral function for feeding.
92541.............................. Spontaneous nystagmus test,
including gaze and fixation
nystagmus, with recording.
92542.............................. Positional nystagmus test, minimum
of 4 positions, with recording.
92543.............................. Caloric vestibular test, each
irrigation (binaural, bithermal
stimulation constitutes four
tests), with recording.
92544.............................. Optokinetic nystagmus test,
bidirectional, foveal or
peripheral stimulation, with
recording.
[[Page 37235]]
92545.............................. Oscillating tracking test, with
recording.
92546.............................. Sinusoidal vertical axis rotational
testing.
92547.............................. Use of vertical electrodes (List
separately in addition to code for
primary procedure).
92548.............................. Computerized dynamic posturography.
92551.............................. Screening test, pure tone, air
only.
92552.............................. Pure tone audiometry (threshold);
air only.
92553.............................. Pure tone audiometry (threshold);
air and bone.
92555.............................. Speech audiometry threshold.
92556.............................. Speech audiometry threshold; with
speech recognition.
92557.............................. Comprehensive audiometry threshold
evaluation and speech recognition
(92553 and 92556 combined).
92559.............................. Audiometric testing of groups.
92560.............................. Bekesy audiometry; screening.
92561.............................. Bekesy audiometry; diagnostic.
92562.............................. Loudness balance test, alternate
binaural or monaural.
92563.............................. Tone decay test.
92564.............................. Short increment sensitivity index
(SISI).
92565.............................. Stenger test, pure tone.
92567.............................. Tympanometry (impedance testing).
92568.............................. Acoustic reflex testing; threshold.
92569.............................. Acoustic reflex testing; decay.
92571.............................. Filtered speech test.
92572.............................. Staggered spondaic word test.
92573.............................. Lombard test.
92575.............................. Sensorineural acuity level test.
92576.............................. Synthetic sentence identification
test.
92579.............................. Visual reinforcement audiometry
(VRA)
92582.............................. Conditioning play audiometry.
92583.............................. Select picture audiometry.
92584.............................. Electrocochleography.
92585.............................. Auditory evoked potentials for
evoked response audiometry and/or
testing of the central nervous
system; comprehensive.
92586.............................. Auditory evoked potentials for
evoked response audiometry and/or
testing of the central nervous
system; limited.
92587.............................. Evoked otoacoustic emissions;
limited (single stimulus level,
either transient or distortion
products).
92588.............................. Evoked otoacoustic emissions;
comprehensive or diagnostic
evaluation (comparison of
transient and/or distortion
product otoacoustic emissions at
multiple levels and frequencies).
92596.............................. Ear protector attenuation
measurements.
92597.............................. Evaluation for use and/or fitting
of voice prosthetic device to
supplement oral speech.
92601.............................. Diagnostic analysis of cochlear
implant, patient under 7 years of
age; with programming.
92602.............................. Diagnostic analysis of cochlear
implant, patient under 7 years of
age; subsequent reprogramming.
92603.............................. Diagnostic analysis of cochlear
implant, age 7 years or older;
with programming.
92604.............................. Diagnostic analysis of cochlear
implant, age 7 years or older;
subsequent reprogramming.
92605.............................. Evaluation for prescription of non-
speech-generating augmentative and
alternative communication device.
92606.............................. Therapeutic service(s) for the use
of non-speech-generating device,
including programming and
modification.
92607.............................. Evaluation for prescription for
speech-generating augmentative and
alternative communication device,
face-to-face with the patient;
first hour.
92608.............................. Evaluation for prescription for
speech-generating augmentative and
alternative communication device,
face-to-face with the patient;
each additional 30 minutes (List
separately in addition to code for
primary procedure).
92609.............................. Therapeutic services for the use of
speech-generating device,
including programming and
modification
92610.............................. Evaluation of oral and pharyngeal
swallowing function.
92611.............................. Motion fluoroscopic evaluation of
swallowing function by cine or
video recording.
92612.............................. Flexible fiberoptic endoscopic
evaluation of swallowing by cine
or video recording.
92614.............................. Flexible fiberoptic endoscopic
evaluation, laryngeal sensory
testing by cine or video
recording.
92616.............................. Flexible fiberoptic endoscopic
evaluation of swallowing and
laryngeal sensory testing by cine
or video recording.
92620.............................. Evaluation of central auditory
function, with report; initial 60
minutes.
92621.............................. Evaluation of central auditory
function, with report; each
additional 15 minutes.
92625.............................. Assessment of tinnitus (includes
pitch, loudness matching, and
masking).
------------------------------------------------------------------------
9. HCPAC Codes
a. Podiatric Services
[If you choose to comment on issues in this section, please include
the caption ``DISCUSSION OF COMMENTS--HCPAC CODES'' at the beginning of
your comments.]
We submitted the podiatric services in Table 50 for review.
Table 50
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
10060.............................. Incision and drainage of abscess
(e.g., carbuncle, suppurative
hidradenitis, cutaneous or
subcutaneous abscess, cyst,
furuncle, or paronychia); simple
or single.
11040.............................. Debridement; skin, partial
thickness.
[[Page 37236]]
11041.............................. Debridement; skin, full thickness.
11042.............................. Debridement; skin, and subcutaneous
tissue.
11730.............................. Avulsion of nail plate, partial or
complete, simple; single.
29580.............................. Strapping; Unna boot.
------------------------------------------------------------------------
HCPAC Recommendation
The HCPAC agreed with the specialty society that there was
compelling evidence that the valuation of these services was incorrect
due to a flawed methodology used in the previous Harvard valuation for
all six podiatric codes. Based on the survey data, the specialty
society requested that the work RVU increase for four codes and
decrease for two codes.
For CPT codes 10060 and 29580, the HCPAC supported an increase in
the existing work values for these codes and recommended a work RVU of
1.50 for CPT code 10060 and 0.60 for CPT code 29580, which represent
the survey median of the survey data for these services.
For CPT code 11040, the HCPAC did not support the work RVU increase
recommended by the specialty society, but instead recommended a work
RVU of 0.55, which represented the 25th percentile work RVU from the
survey data.
For CPT codes 11041 and 11730, the HCPAC recommended a decrease in
the work RVUs and, based on the median from the survey data,
recommended a work RVU of 0.80 for CPT code 11041 and 1.10 for CPT code
11730.
For CPT code 11042, the HCPAC did not agree with the specialty
society that the work RVU should be increased to 1.20 work RVUs. The
HCPAC recommended maintaining the current work RVU of 1.12 for this CPT
code, which was slightly higher than the survey's 25th percentile work
value of 1.10 work RVUs.
The HCPAC-recommended work values for these services are as
follows: 10060 = 1.50 work RVUs; 11040 = 0.55 work RVUs; 11041 = 0.80
work RVUs; 11042 = 1.12 work RVUs; 11730 = 1.10 work RVUs; and 29580 =
0.60 work RVUs.
CMS Proposed Valuation
For CPT code 10060, we compared the survey times them with the
current Harvard-based times used to value this service. These times are
comparable and, therefore, we are recommending maintaining the current
work RVUs of 1.17 for this code.
For CPT code 29580, we compared the current Harvard-based times
with the survey times. Due to the small reduction in time, the
recommended increase in work RVUs is not supported. Therefore, we are
proposing to assign 0.55 work RVUs to this service, which represents
the 25th percentile of the survey and more accurately represents the
time associated with this service.
For CPT code 11730, the current work RVUs are slightly more (0.03)
than the recommended value and the survey time is approximately 30
percent greater than the current Harvard-based time. For these reasons,
we agree with the HCPAC's recommendation of 1.10 work RVUs for 11730
which represents the median survey value.
For CPT codes 11040, 11041 and 11042, the survey times all reflect
significant reductions from current Harvard-based times used to value
these services. Based on this comparison which shows decreases in time
ranging from 47 percent to 68 percent, we believe that the low values
from the surveys more accurately represent the valuation of these
services. Therefore, we are proposing to assign work RVUs as follows:
11040 = 0.48 work RVUs; 11041 = 0.60 work RVUs; and 11042 = 0.80 work
RVUs. In addition, to ensure that the other codes in this family are
properly valued, we recommend the RUC should review the valuation of
CPT codes 11043 and 11044.
b. Other HCPAC Codes
The American Dietetic Association submitted five CPT and HCPCS
codes related to medical nutrition services that were referred to the
CPT Editorial Panel (see Table 51).
Table 51
------------------------------------------------------------------------
CPT code Descriptor
------------------------------------------------------------------------
97802.............................. Medical nutrition therapy; initial
assessment and intervention,
individual, face-to-face with the
patient, each 15 minutes.
97803.............................. Medical nutrition therapy; re-
assessment and intervention,
individual, face-to-face with the
patient, each 15 minutes.
97804.............................. Medical nutrition therapy; group (2
or more individual(s)), each 30
minutes G0270 Medical nutrition
therapy; reassessment and
subsequent intervention(s)
following second referral in same
year for change in diagnosis,
medical condition, or treatment
regimen (including additional
hours needed for renal disease),
individual, face to face with the
patient, each 15 minutes.
G0270.............................. Medical nutrition therapy;
reassessment and subsequent
intervention(s) following second
referral in same year for change
in diagnosis, medical condition,
or treatment regimen (including
additional hours needed for renal
disease), individual, face to face
with the patient, each 15 minutes.
G0271.............................. Medical nutrition therapy;
reassessment and subsequent
intervention(s) following second
referral in same year for change
in diagnosis, medical condition,
or treatment regimen (including
additional hours needed for renal
disease), group (2 or more
individuals), each 30 minutes.
------------------------------------------------------------------------
Additionally, the ASHA submitted CPT code 96105, Assessment of
aphasia (includes assessment of expressive and receptive speech and
language function, language comprehension, speech production ability,
reading, spelling, writing, e.g., by Boston Diagnostic Aphasia
Examination) with interpretation and report, per hour, for review but
subsequently withdrew this code.
C. Other Issues Under the 5-Year Review
[If you choose to comment on issues in this section, please include
the caption ``OTHER ISSUES'' at the beginning of your comments.]
[[Page 37237]]
1. Anesthesia Services
Although anesthesia services are paid under the PFS, they are paid
on the basis of an anesthesia code-specific base unit and time units
that vary based on the anesthesia time of the case. Since anesthesia
services do not have a work value per code as do other medical and
surgical services, a work value must be imputed for each anesthesia
code. For the last 5-Year Review, this imputed work value was compared
to an actual work value determined by the RUC and the ASA through a
building-block approach. Under the building-block approach, each
anesthesia code was uniformly divided into five components: pre-
anesthesia, equipment and supply preparation, induction period, post-
induction anesthesia period, and post-anesthesia. The work was
determined for each of the five components and summed to calculate
total anesthesia work for the anesthesia code.
Although the ASA submitted one anesthesia code and several other
codes for this 5-Year Review, they continue to believe the work of
anesthesia services remain seriously undervalued. The last 5-Year
Review of anesthesia services proved to be a very laborious and
exhaustive process involving several different RUC workgroups. The
valuation of anesthesia work is a very complex process as it involves
relating components of anesthesia services to other medical and
surgical services of similar time and work. The ASA was dissatisfied
with the recommendations made by the RUC for the last 5-Year Review for
anesthesia work. The major points of disagreement were the use and
extent of extrapolation and the work value for the post-induction
anesthesia period, which is the longest period of the anesthesia
service.
For the last 5-Year Review, the ASA requested the RUC to
extrapolate from 19 high volume anesthesia services, which were studied
and accounted for over 50 percent of Medicare payments for anesthesia
services, to all anesthesia services. The RUC thought that
extrapolation should be limited. That is, an analysis of a single
anesthesia code based on a single surgical code was insufficient when
the anesthesia code covers a large number of surgical codes. For the
last 5-Year Review, the building-block approach used a value of 0.025
for the IWPUT for the post-induction anesthesia period. This was a
value that the RUC agreed to, which we approved, although the ASA
thought it was too low.
As a result of its relationship with the RUC and the past
recommendations, the ASA requested that we address the valuation of
anesthesia services reported under CPT codes 00100 through 01999. The
ASA furnished an analysis that builds on the methodology used in the
last 5-Year Review for the valuation of work for anesthesia services.
Based on comparable physicians' services, the ASA believes that the
more appropriate IWPUT for the post-induction period is 0.043. Using
this IWPUT, the ASA calculated a scaling factor and used this to
recalculate the post-induction work value and an adjusted total work
RVU for each of the 19 codes. Based on an extrapolation from the 19
surveyed services used in the last 5-Year Review, the ASA proposed that
the anesthesia work value should be increased by 37.5 percent. The
extrapolation proposed by the ASA is more far reaching than the
extrapolation used by the RUC in the last 5-Year Review. We do not
favor using extrapolation other than on the limited basis it was used
in the last 5-Year Review.
Since the ASA believes that the RUC process does not work well for
their codes, they requested that we directly evaluate their
recommendations independent of any RUC review of input. Although there
may be some merit to the ASA approach, we believe this analysis is more
appropriately done by a multispecialty workgroup within the RUC itself.
Thus, we are recommending the valuation of anesthesia services, namely
the proposed valuation of the post-induction time period, be referred
to the RUC for their review and consideration. For example, the ASA and
the RUC could review the IWPUT for post-induction time, as currently
proposed by the ASA and compare this to the corresponding IWPUT
recognized in the last 5-Year Review of anesthesia work for the 19
surveyed codes.
A second issue concerning anesthesia services pertains to the
impact of the revised work values for E/M services and their
relationship to the valuation of pre- and post-anesthesia services,
components of the building-block approach. The pre- and post-anesthesia
services derive their work values from the lower level E/M codes for
new patients, the subsequent hospital care codes and the initial
inpatient consultation codes. We are proposing to substitute the
proposed revised work values for E/M codes where applicable and
recompute the anesthesia work values and their impact on the increase
in total anesthesia work. While this results in a very minor adjustment
to anesthesia work (that is, less than 1 percent), we believe this
approach provides for the consistent application of the proposed work
RVUs changes.
2. Discussion of Post-Operative Visits Included in the Global Surgical
Packages
We have established a national definition for a global surgical
package so that payment is made consistently for the same set of
services across all contractor jurisdictions. In constructing the RVUs
for a global surgery service, all services that are believed to be
typically included in the defined global period are built into the
final resource-based RVUs and are not separately billable within the
defined global period; this is reflected in the proposed work RVUs in
Addenda B and C. This would include pre-surgery work, the intra-service
time of actually performing the surgical procedure, and the post-
operative (follow-up) visits associated with the monitoring and
recovery of the patient.
As stated above in this section, we are proposing to apply the RUC-
recommended new values for the E/M services to all surgical services
with a 10 or 90-day global period. However, because of variations in
the patient population and in practice patterns, there is some question
whether the assumptions about the number and level of visits within the
global period reflect the actual post-operative work performed. Some
surgeons have commented to us that they perform more visits than are
included in the global period for their services. It is also likely
that some patients require fewer than the ``typical'' number of follow-
up visits included in the global period.
Although we are not proposing any changes to our global policy at
this time, we would be interested in receiving comments concerning our
current policy of including these post-operative visits in the global
surgical packages and what advantages or disadvantages might be
associated with proposing a change to this policy in the future.
3. Codes Referred to CPT Editorial Panel From Five-Year Review of Work
Relative Value Units
[[Page 37238]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.051
[[Page 37239]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.052
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[GRAPHIC] [TIFF OMITTED] TN29JN06.053
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[GRAPHIC] [TIFF OMITTED] TN29JN06.054
BILLING CODE 4120-01-C
4. Budget Neutrality
Section 1848(c)(2)(B)(ii) of the Act requires that increases or
decreases in RVUs for a year may not cause the amount of expenditures
for the year to differ by more than $20 million from what expenditures
would have been in the absence of these changes. If this threshold is
exceeded, we must make adjustments to preserve budget neutrality. This
year, we expect that budget-neutrality adjustments will be required as
a result of changes in RVUs resulting from the 5-Year Review. Revisions
in payment policies, including the establishment of interim and final
RVUs for coding changes that will be announced later this year, may
result in additional budget-neutrality adjustments.
We considered making the statutorily required budget-neutrality
adjustments (under section 1848(c)(2)(B)(ii) of the Act) to account for
the 5-Year Review of physician work by reducing all work RVUs. We
currently estimate that all work RVUs would have to be reduced by 10
percent under this option. Alternatively, we considered making an
adjustment to the PFS CF to meet the provisions of section
1848(c)(2)(B)(ii). This option would require an estimated 5 percent
reduction in the CF. We note that the application of the budget
neutrality adjustment to the CF would negatively impact all PFS
services; whereas the application of the budget neutrality adjustment
to the work RVUs would impact only those services that have physician
work RVUs. Because the need for a budget neutrality adjustment would be
largely due to changes proposed as a result of the 5-Year Review of
work RVUs, we believe it is more equitable to apply the adjustment
across services that have work RVUs. For this third 5-Year Review, we
are proposing to establish a budget neutrality adjustor that would
reduce all work RVUs by an estimated 10 percent to meet the budget
neutrality provisions of section 1848(c)(2)(B)(ii).
As we noted in the CY 2005 Physician Fee Schedule final rule with
comment period (69 FR 66371), PE and malpractice expense RVUs were not
subject to comment and will not be recalculated (other than changes to
PE RVUs that result from changes in PE inputs due to changes in
physician time or in the number of post procedure visits as part of the
5-Year Review of work RVUs).
5. Effect on Practice Expense Inputs Stemming From the 5-Year Review
The proposed changes for work RVUs reflect, in part, the
physician's time needed to perform each service, as well as the number
and level of assumed post-operative visits. To the extent that the RUC
recommended changes in the times associated with the intra-service
portion of the procedure, we are also proposing to adjust the clinical
labor time assigned for assisting the physician in the nonfacility
setting. In addition, if an accepted new work RVU reflects a change in
the number or level of post-operative visits, we are proposing to
modify the clinical staff time to reflect the change. This adjusted
time is also applied to the equipment used in the post-operative
visits. Where the number of post-operative visits has changed, the
number of minimum multi-specialty visit (MMSV) packs will also be
adjusted accordingly. A MMSV pack consists of the following supplies:
exam table paper, 2 pairs of non-sterile gloves, a patient gown, a
pillow case, and a thermometer probe cover. These changes in clinical
labor and equipment time and in the quantity of supplies will have a
minimal impact on the PE component.
6. Nature and Format of Comments on Work RVUs
We will accept comments on the proposed work RVUs for the codes
identified in the Addendum C of this notice. We will also accept
comments on the anesthesia code, CPT code 00797. Comments should
discuss how the work associated with a given CPT or HCPCS code is
analogous to the work in other services, or discuss the rationale for
agreeing or disagreeing with the proposed work RVU. We are especially
interested in information or discussions that were not presented in
earlier comments.
D. Resource-Based Practice Expense (PE) RVUs
[If you choose to comment on issues in this section, please include
the caption ``PRACTICE EXPENSE'' at the beginning of your comments.]
Based on section 1848(c)(1)(B) of the Act, practice expense (PE) is
the portion of the resources used in furnishing the service that
reflects the general categories of physician and practitioner expenses,
such as office rent and wages of personnel, but excluding malpractice
expenses.
[[Page 37242]]
Section 121 of the Social Security Amendments of 1994 (Pub. L. 103-
432), enacted on October 31, 1994, required CMS to develop a
methodology for a resource-based system for determining PE RVUs for
each physician's service. Until that time, physicians' PEs were based
on historical allowed charges. This legislation stated that the revised
PE methodology must consider the staff, equipment, and supplies used in
the provision of various medical and surgical services in various
settings beginning in 1998. The Secretary has interpreted this to mean
that Medicare payments for each service would be based on the relative
PE resources typically involved with performing the service.
The initial implementation of resource-based PE RVUs was delayed
from January 1, 1998, until January 1, 1999, by section 4505(a) of the
Balanced Budget Act of 1997 (BBA 97) (Pub. L. 105-33). In addition,
section 4505(b) of the BBA 97 required that the new payment methodology
be phased-in over 4 years, effective for services furnished in CY 1999,
and fully effective in CY 2002. The first step toward implementation of
the statute was to adjust the PE values for certain services for CY
1998. Section 4505(d) of BBA 97 required that, in developing the
resource-based PE RVUs, the Secretary must:
Use, to the maximum extent possible, generally accepted
cost accounting principles that recognize all staff, equipment,
supplies, and expenses, not solely those that can be linked to specific
procedures.
Develop a refinement method to be used during the
transition.
Consider, in the course of notice and comment rulemaking,
impact projections that compare new proposed payment amounts to data on
actual physician PEs.
Beginning in CY 1999, we began the four year transition to
resource-based PE RVUs. In CY 2002, the resource-based PE RVUs were
fully transitioned.
1. Current Methodology
The following sections discuss the current PE methodology.
a. Data Sources
There are two primary data sources used to calculate PE. The AMA's
Socioeconomic Monitoring System (SMS) survey data are used to develop
the PE per hour (PE/HR) for each specialty. The second source of data
used to calculate PE was originally developed by the Clinical Practice
Expert Panels (CPEP). The CPEP data include the supplies, equipment and
staff times specific to each procedure.
The AMA developed the SMS survey in 1981 and discontinued it in
1999. Beginning in 2002, we incorporated the 1999 SMS survey data into
our calculation of the PE RVUs, using a 5-year average of SMS survey
data. (See Revisions to Payment Policies and Five-Year Review of and
Adjustments to the Relative Value Units Under the Physician Fee
Schedule for CY 2002 final rule, published November 1, 2001 (66 FR
55246).) The SMS PE survey data are adjusted to a common year, 1995.
The SMS data provide the following six categories of PE costs:
Clinical payroll expenses, which are payroll expenses
(including fringe benefits) for nonphysician personnel.
Administrative payroll expenses, which are payroll
expenses (including fringe benefits) for nonphysician personnel
involved in administrative, secretarial or clerical activities.
Office expenses, which include expenses for rent, mortgage
interest, depreciation on medical buildings, utilities and telephones.
Medical material and supply expenses, which include
expenses for drugs, x-ray films, and disposable medical products.
Medical equipment expenses, which include expenses
depreciation, leases, and rent of medical equipment used in the
diagnosis or treatment of patients.
All other expenses, which include expenses for legal
services, accounting, office management, professional association
memberships, and any professional expenses not mentioned above.
In accordance with section 212 of the Medicare, Medicaid and State
Child Health Insurance Program Balanced Budget Refinement Act of 1999
(BBRA) (Pub. L. 106-113), we established a process to supplement the
SMS data for a specialty with data collected by entities and
organizations other than the AMA (that is, the specialty itself). (See
the Criteria for Submitting Supplemental Practice Expense Survey Data
interim final rule with comment period, published on May 3, 2000 (65 FR
25664).) Originally, the deadline to submit supplementary survey data
was through August 1, 2001. In the Revisions to Payment Policies and
Five-Year Review of and Adjustments to the Relative Value Units Under
the Physician Fee Schedule for CY 2002 final rule (November 1, 2001; 66
FR 55246), the deadline was extended through August 1, 2003. To ensure
maximum opportunity for specialties to submit supplementary survey
data, we extended the deadline to submit surveys until March 1, 2005 in
the Revisions to Payment Policies Under the Physician Fee Schedule for
CY 2004 final rule, (November 7, 2003; 68 FR 63196) (hereinafter
referred to as CY 2004 PFS final rule).
The CPEPs consisted of panels of physicians, practice
administrators, and nonphysicians (registered nurses (RNs), for
example) who were nominated by physician specialty societies and other
groups. There were 15 CPEPs consisting of 180 members from more than 61
specialties and subspecialties. Approximately 50 percent of the
panelists were physicians.
The CPEPs identified specific inputs involved in each physician
service provided in an office or facility setting. The inputs
identified were the quantity and type of nonphysician labor, medical
supplies, and medical equipment.
In 1999, the AMA's RUC established the Practice Expense Advisory
Committee (PEAC). Since 1999, and until March 2004, the PEAC, a multi-
specialty committee, reviewed the original CPEP inputs and provided us
with recommendations for refining these direct PE inputs for existing
CPT codes. Through its last meeting in March 2004, the PEAC provided
recommendations, which we have reviewed and accepted, for over 7,600
codes. As a result, the current CPEP inputs differ markedly from those
originally recommended by the CPEPs. The PEAC has now been replaced by
the Practice Expense Review Committee (PERC), which acts to assist the
RUC in recommending PE inputs.
b. Allocation of PEs to Services
To establish PE RVUs for specific services, it is necessary to
establish the direct and indirect PE associated with each service. Our
current approach allocates aggregate specialty practice costs to
specific procedures and, thus, is often referred to as a ``top-down''
approach. The specialty PEs are derived from the AMA's SMS survey and
supplementary survey data. The PEs for a given specialty are allocated
to the services performed by that specialty on the basis of the CPEP
data and work RVUs assigned to each CPT code. The specific process is
detailed as follows:
Step 1--Calculation of the SMS Cost Pool for Each Specialty
The six SMS cost categories can be described as either direct or
indirect expenses. The three direct expense categories include clinical
labor, medical supplies and medical equipment. Indirect expenses
include administrative labor, office expense, and
[[Page 37243]]
all other expenses. We combine these indirect expenses into a single
category. The SMS cost pool for each specialty is calculated as
follows:
The specialty PE/HR for each of the three direct and one
indirect cost categories from the SMS is calculated by dividing the
aggregate PE per specialty by the specialty's total hours spent in
patient care activities (also determined by the SMS survey). The PE/HR
is divided by 60 to obtain the PE per minute (PE/MIN).
Each specialty's PE pools (for each of the three direct
and one indirect cost categories) are created by multiplying the PE/MIN
for the specialty by the total time the specialty spent treating
Medicare patients for all procedures (determined using Medicare
utilization data). Physician time on a procedure-specific level is
available through RUC surveys of new or revised codes and through
surveys conducted as part of the 5-Year Review process. For codes that
the RUC has not yet reviewed, the original data from the Harvard
resource-based RVU system survey are used. Physician time includes time
spent on the case prior to, during, and after the procedure. The
physician procedure time is multiplied by the frequency that each
procedure is performed on Medicare patients by the specialty.
The total specialty-specific SMS PE for each cost category
is the sum, for each direct and indirect cost category, of all of the
procedure-specific total PEs.
Step 2--Calculation of CPEP Cost Pool
CPEP data provide expenditure amounts for the direct expense
categories (clinical labor, supplies and equipment cost) at the
procedure level. Multiplying the CPEP procedure-level PEs for each of
these three categories by the number of times the specialty provided
the procedure, produces a total category cost, per procedure, for that
specialty. The sum of the total expenses from each procedure results in
the total CPEP category cost for the specialty.
Step 3--Calculation and Application of Scaling Factors
This step ensures that the total of the CPEP costs across all
procedures performed by the specialty equates with the total direct
costs for the specialty as reflected by the SMS data. To accomplish
this, the CPEP data are scaled to SMS data by a scaling factor so that
the total CPEP costs for each specialty equals the total SMS cost for
the specialty. (The scaling factor is calculated by dividing the
specialty's SMS pool by the specialty's CPEP pool.)
The unscaled CPEP cost per procedure value, at the direct cost
level, is then multiplied by the respective specialty scalar to yield
the scaled CPEP procedure value. The sum of the scaled CPEP direct cost
pool expenditures equals the total scaled direct expense for the
specific procedure at the specialty level.
Step 4--Calculation of Indirect Expenses
Indirect PEs cannot be directly attributed to a specific service
because they are incurred by the practice as a whole. Indirect costs
include rent, utilities, office equipment and supplies, and accounting
and legal fees. There is not a single, universally accepted approach
for allocating indirect practice costs to individual procedure codes.
Rather allocation involves judgment in identifying the base or bases
that are the best measures of a practice's indirect costs.
To allocate the indirect PEs to a specific service, we use the
following methodology:
The scaled direct expenses and the converted work RVU (the
work RVU for the service is multiplied by $34.5030, the 1995 CF) are
added together, and then multiplied by the number of services provided
by the specialty to Medicare patients;
The total indirect PEs per specialty are calculated by
summing the indirect expenses for all other procedures provided by that
specialty.
Step 5--Calculation and Application of Indirect Scaling Factors
Similar to the direct costs, the indirect costs are scaled to
ensure that the total across all procedures performed by the specialty
equates with the total indirect costs for the specialty as reflected by
the SMS data. To accomplish this, the indirect costs calculated in Step
4 are scaled to SMS data. The calculation of the indirect scaling
factors is as follows:
The specialty's total SMS indirect expense pool is divided
by the specialty's total indirect expense pool calculated in Step 4, to
yield the indirect expense scaling factor.
The unscaled indirect expense amount, at the procedure
level, is multiplied by the specialty's scaling factor to calculate the
procedure's scaled indirect expenses.
The sum of the scaled indirect expense amount and the
procedure's direct expenses yields the total PEs for the specialty for
this procedure.
Step 6--Weighted Average of RVUs for Procedures Performed by More Than
One Specialty
For codes that are performed by more than one specialty, a weighted
average PE is calculated based on Medicare frequency data of all
specialties performing the procedure.
Step 7--Budget Neutrality and Final RVU Calculation
Section 1848(c)(2)(B)(ii)(II) of the Act provides that adjustments
in RVUs may not cause total PFS payments to differ by more than $20
million from what they would have been if the adjustments were not
made. If the aggregate adjustments to PE RVUs would cause PFS
expenditures to exceed the $20 million threshold, the total scaled
direct and indirect inputs are then adjusted by a budget neutrality
factor (BNF) to calculate RVUs. Budget neutrality for the upcoming year
is determined relative to the sum of PE RVUs for the current year.
Although the PE RVUs for any particular code may vary from year-to-
year, the sum of PE RVUs across all codes is set equal to the current
year. The BNF is equal to the sum of the current year's PE RVUs,
divided by the sum of the direct and indirect inputs across all codes
for the upcoming year. The BNF is applied to (multiplied by) the scaled
direct and indirect expenses for each code to set the PE RVU for the
upcoming year.
c. Other Methodological Issues: Non-Physician Work Pool (NPWP)
As an interim measure, until we could further analyze the effect of
the top-down methodology on the Medicare payment for services with no
physician work (including the technical components (TCs) of radiation
oncology, radiology and other diagnostic tests), we created a separate
PE pool for these services. However, any specialty society could
request that its services be removed from the non-physician work pool
(NPWP). We will remove services from the NPWP if we find that the
requesting specialty provides the service the majority of the time.
NPWP Step 1--Calculation of the SMS Cost Pool for Each Specialty
This step parallels the calculations described above for the
standard ``top-down'' PE allocation methodology. For codes in the NPWP,
the direct and indirect SMS costs are set equal to the weighted average
of the PE/HR for the specialties that provide the services in the pool.
Clinical staff time is substituted for physician time in the
calculation. The clinical staff time for the code is from CPEP data.
Otherwise,
[[Page 37244]]
the calculation is similar to the method described previously for codes
with physician time.
NPWP Step 2--Calculation of Charge-based PE RVU Cost Pool
The NPWP calculation uses the 1998 (charge-based) PE RVU value for
the code, multiplied by the 1995 CF (25.74 x $34.503 = $888.11). The
percentage of clinical labor, supplies and equipment are the percentage
that each PE category represents for all physicians relative to the
total PE for all physicians (calculated from the SMS data).
NPWP Step 3--Calculation and Application of Scaling Factors
After the total cost pools for each specialty and code performed by
the specialty are calculated, the steps to ensure the total costs for
all of the procedures performed by a specialty do not exceed the total
costs for the specialty (scaling) are the same as those described
previously for codes with physician work.
NPWP Step 4--Calculation of Indirect Expenses
Because codes in the NPWP do not have work RVUs, indirect expenses
are set equal to direct expenses (for codes with physician work,
indirect expenses equal the sum of the scaled direct expenses and the
converted work RVU). This amount is then multiplied by the number of
times the procedure is performed.
NPWP Step 5--Calculation and Application of Indirect Scaling Factors
Similar to the direct costs, the indirect costs are scaled to
ensure that the total of the charge-based PE RVU costs across all
procedures equates with the total indirect costs as reflected by the
SMS data for the NPWP. To accomplish this, the charge-based data are
scaled to SMS data so the total charge-based costs equal the total SMS
costs.
NPWP Step 6--Budget Neutrality and Final RVU Calculation
Similar to the calculation for codes with physician work, when a
budget neutrality adjustment is necessary, the BNF is applied to
(multiplied by) the scaled direct and indirect expenses for each code
to set the PE RVU for the upcoming year.
d. Facility/Non-facility Costs
Procedures that can be performed in a physician's office, as well
as in a hospital have two PE RVUs: Facility and non-facility. The non-
facility setting includes physicians' offices, patients' homes,
freestanding imaging centers, and independent pathology labs. Facility
settings include hospitals, ambulatory surgical centers (ASCs), and
skilled nursing facilities (SNFs). The methodology for calculating the
PE RVU is the same for both facility and non-facility RVUs, but is
applied independently to yield two separate PE RVUs. Because the PEs
for services provided in a facility setting are generally included in
the payment to the facility (rather than the payment to the physician
under the fee schedule), the PE RVUs are generally lower for services
provided in the facility setting.
2. PE Proposals Methodology for CY 2006
The following discussions outline the specific PE related proposals
for CY 2007.
We have three major goals for our resource-based PE methodology:
To ensure that the PE portion of PFS payments reflect, to
the greatest extent possible, the relative resources required for each
of the services on the PFS. This could only be accomplished by using
the best available data to calculate the PE RVUs.
To develop a payment system for PE that is understandable
and at least somewhat intuitive, so that specialties could better
predict the impacts of changes in the PE data.
To stabilize the PE portion of PFS payments so that
changes in PE RVUs do not produce large fluctuations in the payment for
given procedures from year-to-year.
These goals have also been supported in numerous comments we have
received from the medical community.
In the CY 2006 PFS proposed rule (70 FR 45764), we proposed the
following changes to the PE methodology that we believed would help in
achieving our three major goals (stated above in this section):
Using the PE/HR data from seven specialty-specific
supplementary surveys.
Calculating the direct PE using a bottom-up methodology.
Eliminating the NPWP.
We also proposed an indirect PE methodology that was to assign to
each service the higher of the current indirect PE RVUs or the indirect
PE RVUs calculated using the supplementary survey data.
In the CY 2006 PFS final rule with comment period (70 FR 70116), we
withdrew these proposals primarily because a programming error for the
indirect PE RVU calculation had led to the publication of inaccurate
proposed PE RVUs. On February 15, 2006, we sponsored a PE Town Hall
Meeting and invited the public, including all specialty representatives
to attend. At this meeting, we supplied a detailed description of the
bottom-up approach to the calculation of resource-based PE RVUs. Three
examples were examined in detail that illustrated the impact of the
various assumptions that could be used under a bottom-up approach. We
specifically requested input from all interested parties on possible
changes to our PE methodology, including the move to a bottom-up
approach and the various methods of calculating indirect PE.
We have reviewed the approximately 35 comments that we received in
response to our solicitation. Many of the comments were combined
efforts from related specialty organizations. Additionally, the AMA RUC
also supplied a letter that captured the comments of nearly 30
specialty organizations. The following is a summary of some of the
comments we received.
Delaying Implementation of Changes to the Current PE
Methodology: There were mixed opinions from commenters on whether we
should proceed with a proposal to use a bottom-up approach. Some
commenters emphasized that the CPEP data has been refined and is now
the best available source of data, and asserted that it should be used
for the calculation of resource-based PE RVUs. Other comments suggested
a delay in changing to a bottom-up approach because of the other issues
that are affecting PFS payments this year (such as, the effect of
imaging payment provisions in the Deficit Reduction Act (DRA), the
impact of the negative update, and the uncertainty regarding the impact
of the 5-Year Review of work RVUs).
Transition to a Bottom-Up Approach: The majority of
commenters requested a minimum one-year transition to a maximum 3-year
transition period to fully implement any change to a bottom-up
approach. All of the commenters supported a transition period whether
or not they supported the implementation of a bottom-up approach.
Use of Supplemental Survey Data: A large number of
commenters stated that, irrespective of what we propose for 2007, the
supplemental survey data that has already been accepted should be used.
Other commenters believed that the supplemental survey data grossly
overstated PEs and should not be utilized in the development of
resource based PE RVUs.
Multi-Specialty PE Survey: The majority of commenters
supported the construction and use of a multi-
[[Page 37245]]
specialty survey to collect PE data. Commenters believed that the
supplemental survey data is inflated and that the SMS survey data are
outdated.
Review Equipment Utilization Assumptions and Interest
Rates: Many commenters supported the review and revision of both the
current utilization assumptions and the interest rates associated with
high cost equipment. Commenters had mixed reactions as to whether the
utilization rates should be higher or lower, and some suggested that we
review the possibility of equipment-specific utilization assumptions
for the future. Most commenters believed that the current 11 percent
interest rate is significantly higher then the actual interest rates
and many commenters suggested a rate of approximately prime plus 2
percent.
Proxy Work RVUs for No Physician Work Services: Commenters
were divided on the assignment of a proxy work RVU to services that
contain no physician work. Some commenters believed that no physician
work services are unfairly penalized under any bottom-up approach,
while other comments stated that the inclusion of a proxy work RVU
would double count the clinical labor associated with the no physician
work services.
After considering the comments we received on the CY 2006 PFS
proposed rule (70 FR 45764) and in response to comments received during
and following the Town Hall meeting, we believe that the use of a
bottom-up methodology for direct costs, use of the supplementary survey
data and elimination of the NPWP would assist us in meeting our goal of
a PE methodology that is equitable, understandable and stable.
Therefore, we are again proposing these changes to our PE methodology.
We are also proposing a change in the methodology used to calculate the
indirect PE for each service that is different than previously
proposed. The following is a summary of our proposals.
a. Use a Bottom-Up Method to Calculate the Direct PEs
We believe that we have consistently made a good faith effort to
ensure fairness in our PE RVU-setting system by using the best data
available at any one time. The reason we did not adopt the bottom-up
methodology originally proposed in 1997 and instead adopted the top-
down methodology finalized in 1998 was because we recognized the
concerns among the physician community that the resource input data
developed in 1995 by the CPEP were less reliable than the aggregate
specialty cost data derived from the SMS process.
However, the situation has now changed. The PEAC/PERC/RUC has
completed the refinement of the original CPEP data and we believe that
the refined PE inputs now, in general, accurately capture the relative
direct costs of performing PFS services. Conversely, although we have
now accepted supplementary survey data from 13 specialties, we have not
received updated aggregate cost data from most specialties. Thus, we
believe that, in the aggregate, the refined CPEP data represent more
reliably the relative direct cost PE inputs for physicians' services.
Therefore, instead of using the top-down approach to calculate the
direct PE RVUs, where the aggregate CPEP/RUC costs for each specialty
are scaled to match the aggregate SMS costs, we propose to adopt a
bottom-up method of determining the relative direct costs for each
service. Under this method, the direct costs would be determined by
adding the costs of the resources (that is, the clinical staff,
equipment and supplies) typically required to provide the service. The
costs of the resources, in turn, would be calculated from the refined
CPEP/RUC inputs in our PE database.
We believe that this proposed change, which was welcomed by most
commenters in the CY 2006 PFS proposed rule, will lead to greater
stability and accuracy in the PE portion of our payment system.
Currently, under the top-down methodology, the need to scale the CPEP
costs to equal the SMS costs meant that any changes in the direct PE
inputs for one service often leads to unexpected results for other
services where the inputs had not been altered. In addition, the
current PE RVUs for a procedure do not necessarily change
proportionately with changes in the direct inputs, creating possible
anomalous values. We believe that our proposed bottom-up methodology
would resolve these issues, so that changes in the PE RVUs would be
more intuitive and would result in fewer surprises.
b. Use the PE/HR Data From the Seven Surveys We Have Previously
Accepted and, in Addition, Use the PE/HR Data From the Survey Submitted
by the National Coalition of Quality Diagnostic Imaging Services
(NCQDIS)
As explained in the CY 2005 PFS final rule with comment period (69
FR 66242), we received surveys from the ACC, the ACR, and the ASTRO by
March 1, 2004. The data submitted by the ACC and the ACR met our
criteria. However, as requested by the ACC and the ACR, we deferred
using their data until issues related to the NPWP could be addressed.
(The survey data from ASTRO did not meet the precision criteria
established for supplemental surveys; therefore, we did not accept or
use it in the calculation of PE RVUs for 2005.)
In March 2005, we also received surveys from the Association of
Freestanding Radiation Oncology Centers (AFROC), the AUA, the AAD, the
JCAAI, the NCQDIS, and a joint survey from the American
Gastroenterological Association (AGA), the American Society of
Gastrointestinal Endoscopy (ASGE) and the American College of
Gastroenterology (ACG).
All the surveys, with the exception of the survey from NCQDIS, met
our criteria. Therefore, we proposed in the CY 2006 PFS proposed rule
(70 FR 45775) to use the survey data from all the surveys meeting our
criteria in the calculation of PE RVUs for 2006; but, as discussed in
the CY 2006 PFS final rule with comment period (70 FR 70116) and above
in this section, this proposal was not finalized.
We contracted with the Lewin Group (Lewin) to evaluate whether the
supplemental survey data that were submitted met our criteria and to
make recommendations to us regarding their suitability for use in
calculating PE RVUs. As described in the CY 2006 PFS proposed rule (70
FR 45775), Lewin recommended blending the radiation oncology data from
the AFROC survey data with the ASTRO survey data submitted in 2004 to
calculate the PE/HR. According to Lewin, the goal of the AFROC survey
was to represent the population of freestanding radiation oncology
centers only. To develop an overall average for the radiation oncology
PE pool, the Lewin Group recommended we use the AFROC survey for
freestanding radiation oncology centers, and the hospital-based subset
of last year's ASTRO survey. We agreed that this blending of the AFROC
and ASTRO data was a reasonable way to calculate an average PE/HR that
fully reflects the practice of radiation oncology in all settings.
Blending the survey data overcame the initial problem that the ASTRO
data do not meet the precision criteria as discussed in the CY 2005 PFS
final rule (69 FR 66242). In addition, as discussed in the CY 2006 PFS
proposed rule (70 FR 45776), blending of the data allowed for a broader
base of radiation oncology providers to be represented.
Also, as discussed in the CY 2006 PFS proposed rule (70 FR 45764),
Lewin indicated that the survey data submitted
[[Page 37246]]
by the NCQDIS on independent diagnostic testing facilities (IDTFs) did
not meet our precision criterion. However, upon further analysis, Lewin
agreed with NCQDIS' determination that the inclusion of one inaccurate
record skewed the findings outside the acceptable precision range.
Lewin recalculated the precision level at 8.1 percent of the mean PE/HR
(weighted by the number of physicians in the practice). Lewin indicated
that the level of precision for the total PE/HR satisfies the level of
precision requirement, and recommended acceptance of the survey.
We are now proposing to use the PE/HR data from all of the above
surveys, including the NCQDIS survey, in the calculation of the PE RVUs
for 2007. We are again proposing for radiation oncology to use the new
PE/HR derived from combining the AFROC and ASTRO survey data, as
recommended by Lewin.
We propose to use the PE per physician hour figures in Table 52. It
should be noted that the relatively high PE per physician hour values
for IDTFs result from the fact that there are far fewer hours for this
specialty than most others. IDTFs use relatively few physician hours,
so the same practice expenses in the numerator divided by the smaller
denominator results in considerably higher values for practice expenses
per hour. Although these values of PE/HR appear to be outliers, they
actually contribute little to the overall value for practice expenses
per hour, because the volume of each of the services performed by the
IDTFs represents a relatively small percentage of the total services.
Table 52.--Practice Expense Per Physician Hour Figures
--------------------------------------------------------------------------------------------------------------------------------------------------------
Clinical Administrative Office Other
Specialty labor Supplies Equipment expense expense expense
--------------------------------------------------------------------------------------------------------------------------------------------------------
Allergy/Immunology........................................... 65.9 22.5 6.3 56.3 65.9 31.1
Cardiology................................................... 59.6 25.9 18.6 53.3 52.7 25
Dermatology.................................................. 40.6 15.4 11 51.5 78.8 28.2
Gastro-enterology............................................ 30.2 8.2 5.9 39.6 48.4 13.3
IDTF......................................................... 111.6 55 302.5 155.5 121.2 189.5
Radiology.................................................... 29.1 11.3 27.3 37.8 23.9 44.8
Radiation Oncology........................................... 49.7 4.8 27.6 26 39.7 28.1
Urology...................................................... 27.9 14.4 11.2 42.3 53.8 23.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Section 303(a)(1)(B) of the Medicare Prescription Drug,
Improvement, and Modernization Act of 2003 (MMA) (Pub. L. 108-173)
added section 1848(c)(2)(I) of the Act to require CMS to use survey
data submitted by a specialty group where at least 40 percent of the
specialty's payments for Part B services are attributable to the
administration of drugs in 2002 to adjust PE RVUs for drug
administration services. The statute applies to surveys that include
expenses for the administration of drugs and biologicals, and were
received by March 1, 2005 for determining the CY 2006 PE RVUs. Section
303(a)(1)(A)(ii) of the MMA also added section 1848(c)(2)(B)(iv)(II) of
the Act to provide an exemption from budget neutrality in 2005 and 2006
for any additional expenditures resulting from the use of these
surveys. In the Changes to Medicare Payment for Drugs and Physician Fee
Schedule Payments for CY 2004 interim final rule published January 7,
2004 (69 FR 1084), we stated that the specialties of urology,
gynecology, and rheumatology meet the above criteria. As described in
the CY 2006 PFS final rule with comment period (70 FR 70116), we
accepted for the purposes of calculating the 2006 PE RVUs for drug
administration services the new survey data from the AUA and exempted
from the budget neutrality adjustment any impacts of accepting these
data for purposes of calculating PE RVUs for drug administration
services. (Note: Rheumatology and gynecology did not submit
supplemental survey data.)
c. Eliminate the NPWP and Calculate the PE RVUs for All Services Using
the Same Methodology
Primarily because of the lack of representative SMS data or
accurate direct cost inputs for specialties such as radiology and
radiation oncology, the adoption of the top-down approach necessitated
the creation of the NPWP. This separate work pool was created to
allocate PE RVUs for TC codes and codes that are not performed by
physicians and, thus, have no work RVUs. In the CY 2000 Physician Fee
Schedule; Payment Policies and Relative Value Unit Adjustment final
rule, we indicated that ``the purpose of this pool was only to protect
the (TC) services from the substantial decreases'' caused by inaccurate
CPEP data and the lack of physician work RVU in the allocation of the
indirect costs (64 FR 59406). Unfortunately, the services priced by the
NPWP methodology have proven to be especially vulnerable to any change
in the work pool's composition. This has led to significant
fluctuations from year to year in the PE RVUs calculated for these
services.
The major specialties comprising the NPWP (radiology, radiation
oncology and cardiology) have now submitted supplemental survey data
that we have accepted and are proposing to use in their PE
calculations. (See the discussion on supplementary surveys above in
this section.) Now that we have representative aggregate PE data for
these specialties, and with the completion of the refinement of the
direct cost inputs, the continued necessity and equity of treating
these technical services outside the PE methodology applied to other
services is questionable.
Therefore, we are proposing to eliminate the NPWP and to calculate
the PE RVUs for the services currently in the work pool by the same
methodology used for all other services. This would also allow the use
of the refined CPEP/RUC data to price the direct costs of individual
services, rather than utilizing the pre-1998 charge-based PE RVUs. In
addition, this proposal would lead to greater stability for the PE RVUs
for these services and would lead to more intuitive results than have
occurred with the NPWP methodology.
d. Modify the Current Indirect PE RVUs Methodology
As described previously, the SMS and supplementary survey data are
the source for the specialty-specific aggregate indirect costs used in
our PE calculations. We then allocate the indirect costs to particular
codes on the basis of the direct costs allocated to a code and the work
RVUs. In the CY 2006 PFS proposed rule (70 FR 45764), we stated that we
had no information that would indicate that the current indirect PE
methodology is inaccurate. At that time, we also were not aware of
[[Page 37247]]
any alternative approaches or data sources that we could use to
calculate more appropriately the indirect PE, other than the new
supplementary survey data, which we propose to incorporate into our PE
calculations. Therefore, we proposed to use the current indirect PEs in
our calculation, incorporating the new survey data into the codes
performed by the specialties submitting the surveys. We also indicated
in that same proposed rule that we would welcome any suggestions that
would assist us in further refinement of this indirect PE methodology.
For example, we were considering whether we should continue to accept
supplementary survey data or whether it would be preferable and
feasible to have an SMS-type survey of only indirect costs for all
specialties, or whether a more formula-based methodology independent of
the SMS data should be adopted, perhaps using the specialty-specific
indirect-to-total cost percentage as a basis of the calculation. For a
prior discussion of many of the issues associated with allocating
indirect costs, please refer to the CY 2000 Physician Fee Schedule;
Payment Policies and Relative Value Unit Adjustment proposed rule (63
FR 30823).
3. Modifications to PE Proposals
As a result of collaboration with the PFS community and public
comments on this issue, we are now in a position to propose
modifications to the indirect PE methodology.
a. Indirect Percentage Factor: Use of the Specialty-Specific Percentage
That Indirect PEs Represent of Total PEs Based on the Survey Data
We currently allocate indirect expenses on the sum of the direct
expenses and the work RVUs (converted to dollars by multiplying by the
CF). We are proposing to allocate indirect expenses by applying a
specialty-specific indirect percentage factor to the direct expenses in
order to recognize the varying proportion that indirect costs represent
of total costs by specialty. This would have the effect of relatively
increasing the indirect expense allocation for services that are on
average performed by specialties with higher indirect PE percentages,
and relatively decreasing the indirect expense allocation for services
that are performed by specialties with lower indirect PE percentages.
For a given service, the specific indirect percentage factor to apply
to the direct costs for the purpose of the indirect allocation would be
calculated as the weighted average of the ratio of the indirect to
direct costs (based on the survey data) for the specialties that
perform the code. For example, if a service is performed by a single
specialty with indirect PEs that were 75 percent of total PEs, the
indirect percentage factor to apply to the direct costs for the
purposes of the indirect allocation would be (0.75/0.25) = 3.0.
b. Continued Use of the Specialty-Specific Indirect Scaling Factors
As described earlier, we incorporate the indirect PE/HR surveys
into the methodology through the use of specialty-specific indirect
scaling factors. We would continue to use the specialty-specific
indirect scaling factors; however, to apply them in a simpler manner we
propose to create an index. This index would reflect the relationship
between each specialty's indirect scaling factor and the overall
indirect scaling factor for the entire PFS. For example, if a specialty
had an indirect practice cost index of 2.00, this specialty would have
an indirect scaling factor that was twice the overall average indirect
scaling factor. If a specialty had an indirect practice cost index of
0.50, this specialty would have an indirect scaling factor that was
half the overall average indirect scaling factor. The calculation and
application of the indirect practice cost index is described in more
detail below in this section.
c. Use of the Clinical Labor Costs in the Indirect Allocation for a
Service When the Clinical Labor Costs are Greater Than the Physician
Work RVU
We have received numerous comments that services with little or no
physician work RVUs are disadvantaged under our current indirect
allocation methodology based on the direct costs and the work RVUs. In
response to these comments, when the clinical labor portion of the
direct PE RVU is greater than the physician work RVU for a particular
service, we are proposing to allocate on the direct costs and the
clinical labor costs. For example, if a service has no physician work,
the direct PE RVU is 1.10 and the clinical labor portion of the direct
PE RVU is 0.65 RVUs, we would use the 1.10 direct PE RVUs and the 0.65
clinical labor portion of the direct PE RVUs for the indirect PE
allocation for that service. As another example, if the physician work
RVUs for a service are 0.25, the direct PE RVU is 1.10 and the clinical
labor portion of the direct PE RVU is 0.65 RVUs, we would use the 1.10
direct PE RVUs and the 0.65 clinical labor RVUs for the indirect
allocation for that service. We would not use the 0.25 physician work
RVUs for the indirect PE allocation since the 0.65 clinical labor RVUs
are greater than the 0.25 physician work RVUs.
d. Use of 2005 Utilization Data in the Indirect PE RVU Calculation
Under the current PE methodology, we predominately use the 1997-
2000 utilization data in the calculation of the indirect PE RVUs when
the service existed during 1997-2000 or the first year of utilization
data if the service did not exist during that time period. We used
those years of utilization data primarily to increase the year to year
stability of the PE RVUs. With the changes we are proposing to make to
PE RVUs, in particular the elimination of the NPWP, we will increase
the year-to-year stability of the PE RVUs. We believe it is now
appropriate to use updated utilization data in the calculation of the
indirect PEs. We believe the other proposed changes in the PE
methodology will help obtain the year-to-year stability we were
attempting to achieve by continuing to use the older utilization data.
Additionally, the use of more current utilization data would reflect
the more current practice patterns. We are proposing to use the 2005
utilization data in the calculation of the 2007 indirect PE RVUs. We
are also seeking comments on whether the utilization data should be
updated yearly, which would increase the accuracy of the PE
calculations, or less often, which would increase the stability of the
PE RVUs.
e. Elimination of the Special Methodologies for Services With Technical
and Professional Components
Under the PFS, when services have technical, professional, and
global components that can be billed separately, the payment for the
global component equals the sum of the payment for the technical and
professional components. Under the current PE methodology, the
different mix of specialties that perform the global, technical and
professional components can cause the PE RVUs, otherwise created by the
methodology, to fail to add together properly; that is, the global
component does not equal the sum of the professional and technical
components. The global component might exceed the sum of the technical
and professional components or it might be less than the sum of the
technical and professional components. We ensure that the technical and
professional components add to the global component in one of two ways.
For services in the NPWP, we set the PE RVUs for the global component
equal to the sum of the professional component PE RVU and the technical
component
[[Page 37248]]
PE RVU. For services outside the NPWP, we set the PE RVUs for the
technical component equal to the difference between the global PE RVUs
and the professional component RVUs.
With our proposed change to a bottom-up methodology for the direct
PEs, there would be no weighted averaging of the direct costs inputs
necessary to create the direct PE RVUs and, therefore, the direct PE
RVUs for the professional and technical components would sum to the
global component. Under the current methodology, as a result of the
process used to ensure the professional and technical components sum to
the global, RVUs for a service with a global component can be either
more or less than the RVUs that would have been calculated for the
service if the professional and technical components did not have to
sum to the global.
Given the proposed change to bottom-up methodology and the
elimination of the NPWP, we believe it is inappropriate to have codes
for which the global, and the technical and professional components are
assigned RVUs that are either less than or greater than the methodology
would otherwise produce, and thus, are paid at a rate that is either
less than or greater than the methodology would otherwise specify. (See
section II.D.1. of this proposed notice for the discussion of the
current methodology.) Therefore, we are proposing that in the
calculation of the indirect percentage factor described earlier in
section II.D.3.a., we would use a weighted average of the ratio of
indirect to direct costs across all the specialties that perform the
global, technical, and professional components; that is, we would apply
the same weighted average indirect percentage factor to allocate
indirect expenses to the global, professional, and technical components
for a service. We also propose to utilize a similar weighted averaging
approach across all the specialties that perform the components when
calculating the indirect PE scaling factor. Because the direct PE RVUs
for the technical and professional components sum to the global under
the bottom-up methodology, and we are proposing to calculate the
indirect percentage factor and the indirect scaling factor so that they
do not vary between the technical, professional, and global components,
our proposed methodology would create technical and professional
components that sum to the global, and no other special methodology
would need to be employed.
(i) Proposed PE RVU Methodology
Below is a description of the proposed PE RVU methodology.
(a) Setup File
First, we create a setup file for the PE methodology. The setup
file contains the direct cost inputs, the utilization for each
procedure code at the specialty and facility/nonfacility place of
service level, and the specialty-specific survey PE per physician hour
data. Information specific to the creation of the setup file can be
found at the end of section II.D.
(b) Calculate the Direct Cost PE RVUs
Sum the costs of each direct input.
Step 1: Sum the direct costs of the inputs for each service. The
direct costs consist of the costs of the direct inputs for clinical
labor, medical supplies, and medical equipment. The clinical labor cost
is the sum of the cost of all the staff types associated with the
service; it is the product of the time for each staff type and the wage
rate for that staff type. The medical supplies cost is the sum of the
supplies associated with the service; it is the product of the quantity
of each supply and the cost of the supply. The medical equipment cost
is the sum of the cost of the equipment associated with the service; it
is the product of the number of minutes each piece of equipment is used
in the service and the equipment cost per minute. The equipment cost
per minute is calculated as described at the end of this section.
Apply a budget neutrality adjustment to the direct inputs.
Step 2: Calculate the current aggregate pool of direct PE costs. To
do this, multiply the current aggregate pool of total direct and
indirect PE costs (that is, the current aggregate PE RVUs multiplied by
the CF) by the average direct PE percentage from the SMS and
supplementary specialty survey data.
Step 3: Calculate the aggregate pool of proposed direct costs. To
do this, for all PFS services, sum the product of the direct costs for
each service from Step 1 and the utilization data for that service.
Step 4: Using the results of Step 2 and Step 3 calculate a direct
PE budget neutrality adjustment so that the proposed aggregate direct
cost pool does not exceed the current aggregate direct cost pool and
apply it to the direct costs from Step 1 for each service.
Step 5: Convert the results of Step 4 to an RVU scale for each
service. To do this, divide the results of Step 4 by the Medicare PFS
CF.
(c) Create the Indirect PE RVUs
Create indirect allocators.
Step 6: Based on the SMS and supplementary specialty survey data,
calculate direct and indirect PE percentages for each physician
specialty.
Step 7: Calculate direct and indirect PE percentages at the service
level by taking a weighted average of the results of Step 6 for the
specialties that perform the service. Note that for services with
technical and professional components we are calculating the direct and
indirect percentages across the global, professional and technical
components. That is, the direct and indirect percentages for a given
service (for example, echocardiogram) do not vary by the professional,
technical and global components.
Step 8: Calculate the service level allocators for the indirect PEs
based on the percentages calculated in Step 7. The indirect PEs are
allocated based on the three components: the direct PE RVU, the
clinical PE RVU and the work RVU. (Note that the work RVU used in the
calculation includes the separate work budget neutrality adjustment
from the 5-Year Review of the work RVUs discussed elsewhere in this
proposed notice.)
For most services the indirect allocator is: Indirect percentage *
(direct PE RVU/direct percentage) + work RVU.
There are two situations where this formula is modified:
If the service is a global service (that is, a service
with global, professional and technical components), then the indirect
allocator is: indirect percentage * (direct PERVU/direct percentage) +
clinical PE RVU + work RVU.
If the clinical labor PE RVU exceeds the work RVU (and the
service is not a global service), then the indirect allocator is:
indirect percentage * (direct PERVU/direct percentage) + clinical PE
RVU.
Note that for global services the indirect allocator is based on
both the work RVU and the clinical labor PE RVU. We do this to
recognize that, for the professional service, indirect PEs will be
allocated using the work RVUs, and for the technical component
service, indirect PEs will be allocated using the direct PE RVU and
the clinical labor PE RVU. This also allows the global component
RVUs to equal the sum of the professional and technical component
RVUs.)
For presentation purposes in the examples in the Table 53, the
formulas are divided into two parts for each service. The first part
does not vary by service and is the indirect percentage * (direct PE
RVU/direct percentage). The second part is either the work RVU,
clinical PE RVU, or both depending on whether the service is a global
service and whether the clinical PE RVU
[[Page 37249]]
exceeds the work RVU (as described earlier in this step.)
Apply a budget neutrality adjustment to the indirect allocators.
Step 9: Calculate the current aggregate pool of indirect PE RVUs by
multiplying the current aggregate pool of PE RVUs by the average
indirect PE percentage from the physician specialty survey data. This
is similar to the Step 2 calculation for the direct PE RVUs.
Step 10: Calculate an aggregate pool of proposed indirect PE RVUs
for all PFS services by adding the product of the indirect PE
allocators for a service from Step 8 and the utilization data for that
service. This is similar to the Step 3 calculation for the direct PE
RVUs.
Step 11: Using the results of Step 9 and Step 10, calculate an
indirect PE adjustment so that the proposed aggregate indirect
allocation does not exceed the available aggregate indirect PE RVUs and
apply it to indirect allocators calculated in Step 8. This is similar
to the Step 4 calculation for the direct PE RVUs.
Calculate the Indirect Practice Cost Index.
Step 12: Using the results of Step 11, calculate aggregate pools of
specialty-specific adjusted indirect PE allocators for all PFS services
for a specialty by adding the product of the adjusted indirect PE
allocator for each service and the utilization data for that service.
Step 13: Using the specialty-specific indirect PE/HR data,
calculate specialty-specific aggregate pools of indirect PE for all PFS
services for that specialty by adding the product of the indirect PE/HR
for the specialty, the physician time for the service, and the
specialty's utilization for the service.
Step 14: Using the results of Step 12 and Step 13, calculate the
specialty-specific indirect PE scaling factors as under the current
methodology.
Step 15: Using the results of Step 14, calculate an indirect
practice cost index at the specialty level by dividing each specialty-
specific indirect scaling factor by the average indirect scaling factor
for the entire PFS.
Step 16: Calculate the indirect practice cost index at the service
level to ensure the capture of all indirect costs. Calculate a weighted
average of the practice cost index values for the specialties that
perform the service. Note that for services with technical and
professional components, we calculate the indirect practice cost index
across the global, professional and technical components. Under this
method, the indirect practice cost index for a given service (for
example, echocardiogram) does not vary by the professional, technical
and global components.
Step 17: Apply the service level indirect practice cost index
calculated in Step 16 to the service level adjusted indirect allocators
calculated in Step 11 to get the indirect PE RVU.
(d) Calculate the Final PE RVUs
Step 18: Add the direct PE RVUs from Step 6 to the indirect PE RVUs
from Step 17.
Step 19: Calculate and apply the final PE budget neutrality
adjustment by comparing the results of Step 18 to the current pool of
PE RVUs. This final budget neutrality adjustment is primarily required
because certain specialties are excluded from the PE RVU calculation
for ratesetting purposes, but all specialties are included for purposes
of calculating the final budget neutrality adjustment. (See
``Specialties excluded from rate-setting calculation'' below in this
section.)
(e) Setup File Information
Specialties excluded from rate-setting calculation: For
the purposes of calculating the PE RVUs, we exclude certain specialties
such as midlevel practitioners paid at a percentage of the PFS,
audiology, and low volume specialties from the calculation. This is the
same approach used under the current methodology. These specialties are
included for the purposes of calculating the budget neutrality
adjustment.
Crosswalk certain low volume physician specialties:
Crosswalk the utilization of certain specialties with relatively low
PFS utilization to the associated specialties. This is the same
approach used under the current methodology.
Physical therapy utilization: Crosswalk physical therapy
utilization to the specialty of physical therapy. This is the same
approach used under the current methodology.
Identify professional and technical services not
identified under the usual TC and 26 modifier: Flag the services that
are professional and technical component services, but do not use TC
and 26 modifiers (for example, electrocardiograms). This flag
associates the professional and technical component with the associated
global code for use in creating the indirect PE RVU. For example, the
professional service code 93010 is associated with the global code
93000.
Payment modifiers: Payment modifiers are accounted for in
the creation of the file. For example, services billed with the
assistant at surgery modifier are paid 16 percent of the PFS amount for
that service; therefore, the utilization file is modified to only
account for 16 percent of any service that contains the assistant at
surgery modifier.
Proposed work RVUs from the 5-Year Review: The setup file
contains the proposed work RVUs from the 5-Year Review.
The equipment cost per minute is calculated as:
(f) Equipment Cost Per Minute =
(1/(minutes per year * usage)) * price * ((interest rate/(1-(1/((1 +
interest rate) * life of equipment))) + maintenance)
Where:
Minutes per year = maximum minutes per year if usage were
continuous (that is, usage = 1); 150,000 minutes.
Usage = equipment utilization assumption; 0.5.
Price = price of the particular piece of equipment.
Interest rate = 0.11.
Life of equipment = useful life of the particular piece of
equipment.
Maintenance = factor for maintenance; 0.05.
[[Page 37250]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.055
[[Page 37251]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.056
BILLING CODE 4120-01-C
[[Page 37252]]
(ii) Transition the Resulting Revised PE RVUs over a Four-Year Period
A complete analysis of the impacts of these changes is contained in
the impact analysis in section V. of this proposed rule. We are
concerned that, when combined with a proposed negative update factor
for CY 2007 and the proposed changes to the work RVUs under the 5-Year
Review, the shifts in some of the PE RVUs resulting from the immediate
implementation of our proposals could potentially cause some disruption
for medical practices. Therefore, we are proposing to transition the
proposed PE changes over a 4-year period. This would also give ample
opportunity for us, as well as the medical specialties and the RUC, to
identify any anomalies in the PE data, to make any further appropriate
revisions, and to collect additional data as needed prior to the full
implementation of the proposed PE changes.
During the transition period, the PE RVUs would be calculated on
the basis of a blend of RVUs calculated using our proposed methodology
described above (weighted by 25 percent during CY 2007, 50 percent
during CY 2008, 75 percent during CY 2009, and 100 percent
thereinafter), and the current CY 2006 PE RVUs for each existing code.
PE RVUs for codes that are new during this period would be calculated
using only the proposed methodology, and paid at the fully transitioned
rate. We believe that implementing all of these proposed changes would
further our goal of producing a more accurate, more intuitive and more
stable PE methodology.
For example, as stated above in this section, now that the direct
PE inputs have been refined, we believe that the proposed CPEP/RUC
direct input data are superior to the specialty-specific SMS PE/HR data
for the purposes of determining the typical direct PE resources
required to perform each service on the PFS. First, we have received
recommendations on the procedure-specific inputs from the multi-
specialty PEAC that were based on presentations from the relevant
specialties, after the inputs were closely scrutinized by the PEAC
using standards and packages that were agreed upon by all involved
specialties. Second, the refined CPEP/RUC data are more current than
the aggregate specialty-specific data for the majority of specialties.
Third, for direct costs, we believe that it is reasonable to assume
that the costs of the clinical staff, supplies and equipment are the
same for a given service, regardless of the specialty that is
performing it. This does not happen under the top-down direct cost
methodology, where the specialty-specific scaling factors can create
differing direct costs for the same service.
We also believe the proposed methodology is less confusing and more
intuitive than the current approach. First, the NPWP would be
eliminated and all services would be priced using one methodology,
eliminating the complicated calculations needed to price NPWP services.
Second, any revisions made to the direct inputs for one or more
services would now have predictable results. Changes in the direct
practice inputs for a service would proportionately change the PE RVUs
for that service without significantly affecting the PE RVUs for
unrelated services (except, of course, to the extent that a budget
neutrality adjustment is required to be applied by the statute).
The proposed methodology would also create a system that would be
significantly more stable from year-to-year than the current approach.
Specialties should no longer experience the wide fluctuations in
payment for a given service due to an aberrant direct cost scaling
factor. Direct PEs should only change for a service if the service is
further refined or when prices are updated, while indirect PEs should
change only when there are changes in the mix of specialties furnishing
the service or if any future new survey data for indirect costs are
utilized.
We recognize that there may be some outstanding issues that need
further consideration, and we welcome input from the medical community
regarding those issues. We also believe the proposed transition period
would give us the opportunity to work with the affected specialties to
collect any needed data or to determine whether further revisions to
our PE methodology are needed before payment is based entirely on the
proposed methodology. As we gain experience with the new methodology,
we will reexamine this policy beginning next year and propose necessary
revisions through future rulemaking.
Therefore, we welcome all comments on these proposed changes,
particularly those concerning additional modifications to the indirect
PE methodology that might help us further our intended goals.
III. Collection of Information Requirements
This document does not impose information collection and
recordkeeping requirements. Consequently, it need not be reviewed by
the Office of Management and Budget under the authority of the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.)
IV. Response to Comments
Because of the large number of public comments we normally receive
on Federal Register documents, we are not able to acknowledge or
respond to them individually. We will consider all comments received by
the date and time specified in the DATES section of this preamble, and,
we will respond to the comments in the CY 2007 Physician Fee Schedule
final rule with comment period.
V. Regulatory Impact Analysis
[If you choose to comment on issues in this section, please include
the caption ``REGULATORY IMPACT ANALYSIS'' at the beginning of your
comments.]
A. Overall Impact
We have examined the impacts of this proposed notice as required by
Executive Order 12866 (September 1993, Regulatory Planning and Review),
the Regulatory Flexibility Act (RFA) (September 19, 1980, Pub. L. 96-
354), section 1102(b) of the Social Security Act, the Unfunded Mandates
Reform Act of 1995 (Pub. L. 104-4), and Executive Order 13132.
Executive Order 12866 (as amended by Executive Order 13258, which
merely reassigns responsibilities of duties) directs agencies to assess
all costs and benefits of available regulatory alternatives and, if
regulation is necessary, to select regulatory approaches that maximize
net benefits (including potential economic, environmental, public
health and safety effects, distributive impacts, and equity). A
regulatory impact analysis (RIA) must be prepared for major rules with
economically significant effects ($100 million or more in any 1 year).
As indicated in more detail below, we estimate that the PFS work RVU
provisions included in this proposed notice will redistribute more than
$100 million in one year. We are considering this proposed notice to be
economically significant because its provisions are estimated to result
in an increase, decrease or aggregate redistribution of Medicare
spending that will exceed $100 million. Therefore, this proposed notice
is a major rule and we have prepared a regulatory impact analysis.
The RFA requires agencies to analyze options for regulatory relief
of small businesses. For purposes of the RFA, small entities include
small businesses,
[[Page 37253]]
nonprofit organizations, and small governmental jurisdictions. Most
hospitals and most other providers and suppliers are small entities,
either by nonprofit status or by having revenues of $6 million to $29
million in any one year. We prepare a regulatory flexibility analysis
unless we certify that a rule would not have a significant economic
impact on a substantial number of small entities. The analysis must
include a justification concerning the reason action is being taken,
the kinds and number of small entities the rule affects, and an
explanation of any meaningful options that achieve the objectives with
less significant adverse economic impact on the small entities.
Section 1102(b) of the Act requires us to prepare a regulatory
impact analysis if a rule may have a significant impact on the
operations of a substantial number of small rural hospitals. This
analysis must conform to the provisions of section 603 of the RFA. For
purposes of section 1102(b) of the Act, we define a small rural
hospital as a hospital that is located outside a Metropolitan
Statistical Area and has fewer than 100 beds. For purposes of the RFA,
physicians, nonphysician practitioners, and suppliers are considered
small businesses if they generate revenues of $6 million or less.
Approximately 95 percent of physicians are considered to be small
entities. There are over 980,000 physicians, other practitioners and
medical suppliers that receive Medicare payment under the PFS. The
analysis and discussion provided in this section, as well as elsewhere
in this proposed notice, complies with the RFA requirements.
Section 202 of the Unfunded Mandates Reform Act of 1995 also
requires that agencies assess anticipated costs and benefits before
issuing any rule whose mandates require spending in any one year of
$100 million in 1995 dollars, updated annually for inflation. That
threshold level is currently approximately $120 million. Medicare
beneficiaries are considered to be part of the private sector for this
purpose. A discussion concerning the impact of this proposed notice on
beneficiaries is found later in this section.
Executive Order 13132 establishes certain requirements that an
agency must meet when it issues a proposed rule (and subsequent final
rule) that imposes substantial direct requirement costs on State and
local governments, preempts State law, or otherwise has Federalism
implications.
We have examined this proposed notice in accordance with Executive
Order 13132 and have determined that this regulation would not have any
significant impact on the rights, roles, or responsibilities of State,
local, or tribal governments. A discussion concerning the impact of
this proposed notice on beneficiaries is found later in this section.
B. Anticipated Effects
We have prepared the following analysis, which, together with the
information provided in the rest of this preamble, meets all assessment
requirements. It explains the rationale for and purposes of the
proposed notice; details the costs and benefits of the rule; analyzes
alternatives; and presents the measures we propose to use to minimize
the burden on small entities.
Section 1848(c)(2)(B)(ii) of the Act requires that increases or
decreases in RVUs may not cause the amount of expenditures for the year
to differ by more than $20 million from what expenditures would have
been in the absence of these changes. If this threshold is exceeded, we
make adjustments to preserve budget neutrality. This year, the
estimated $4 billion impact of proposed changes in work RVUs resulting
from the 5-year refinement will require that a budget-neutrality
adjustment be made. Revisions in payment policies, including the
establishment of interim and final RVUs for coding changes that will be
announced later this year, may result in additional budget-neutrality
adjustments.
We considered making the statutorily required budget-neutrality
adjustment to account for the 5-Year Review of physician work by
reducing all work RVUs. We estimate that all work RVUs would have to be
reduced by 10 percent under this option. Alternatively, we considered
making the budget neutrality adjustment to the PFS CF. This option
would require an estimated 5 percent reduction in the CF and would also
affect services that do not have work RVUs, and were thus not part of
the 5-Year Review. Therefore, to confine the impact to services that
have physician work RVUs, we are proposing to establish a budget
neutrality adjustor that would reduce the work RVUs by an estimated 10
percent to meet the provisions of section 1848(c)(2)(B)(ii) of the Act.
Table 54 shows the specialty-level impact on payment of the work
and PE changes discussed in this proposed notice for the CY 2007
Medicare PFS, including the effect of the separate work budget
neutrality adjustor discussed above. Because we have proposed a four-
year transition for the new PE changes, we also show the impact of the
fully implemented PE changes in 2010. Our estimates of changes in
Medicare revenues for PFS services compare payment rates for 2006 with
proposed payment rates for 2007 and 2010 using 2005 Medicare
utilization for all years. These impacts do not include estimates of
the annual updates to the Medicare PFS CF for 2007 through 2010. We are
using 2005 Medicare claims processed and paid through March 30, 2005,
that we estimate are 98 percent complete. Using a single year of
utilization, as opposed to multiple years, limits the estimated changes
to the proposed work and PE. This approach is consistent with the
methodology outlined in section II.D.3.d. of this proposed notice,
``Use of 2005 utilization data in the indirect PE RVU calculation.'' To
the extent that there are year-to-year changes in the volume and mix of
services provided by physicians, the actual impact on total Medicare
revenues will be different than those shown here. The payment impacts
reflect averages for each specialty based on Medicare utilization. The
payment impact for an individual physician would be different from the
average, based on the mix of services the physician provides. The
average change in total revenues would be less than the impact
displayed here because physicians furnish services to both Medicare and
non-Medicare patients and specialties may receive substantial Medicare
revenues for services that are not paid under the PFS. For instance,
independent laboratories receive approximately 80 percent of their
Medicare revenues from clinical laboratory services that are not paid
under the PFS.
Table 54 shows only the payment impact on PFS services. The
following is an explanation of the information represented in Table 54:
Specialty: The physician specialty or type of
practitioner/supplier.
Allowed Charges: Allowed charges are the Medicare Fee
Schedule amounts for covered services and include co-payments and
deductibles (which are the financial responsibility of the
beneficiary). These amounts have been summed across all services
provided by physicians, practitioners or suppliers with a specialty to
arrive at the total allowed charges for the specialty.
Impact of Work RVU Changes: The percentage increase or
decrease in allowed charges attributed to changes in the valuation of
physician/clinical work for the given specialty.
Impact of PE RVU Changes: The percentage increase or
decrease in allowed charges attributed to changes in the valuation of
practice expense for the services provided by physicians,
[[Page 37254]]
practitioners or suppliers within each specialty (shown in the first
year of phase-in (2007) and at full implementation (2010)).
Combined impact of Work and PE RVU changes: The percentage
increase or decrease in allowed charges attributed to the sum of
changes to the valuation of physician/clinical work and the valuation
of practice expense for services provided by physicians, practitioners
or suppliers within each specialty (shown in the first year of phase-in
of PE changes (2007) and at full implementation of PE changes (2010)).
BILLING CODE 4120-01-P
[[Page 37255]]
[GRAPHIC] [TIFF OMITTED] TN29JN06.057
This is the third 5-Year Review of physician work RVUs. The first
5-Year Review occurred as part of the 1996 regulatory process and was
effective for services furnished on or after January 1, 1997. The
second 5-Year Review of
[[Page 37256]]
physician work RVUs occurred as part of the 2001 regulatory process and
was effective for services furnished on or after January 1, 2002. Table
55 compares some basic data points from the three 5-Year Reviews.
[GRAPHIC] [TIFF OMITTED] TN29JN06.058
BILLING CODE 4120-01-C
We are currently developing the CY 2007 PFS proposed rule that will
contain our estimate of all other proposed policies and changes that
will affect payment for PFS services in CY 2007. We will show the
combined impact of all policy and other changes affecting PFS payments
in the final CY 2007 PFS rule.
C. Alternatives Considered
This proposed notice discusses the proposed revisions to the work
RVUs under the PFS. The preamble provides descriptions of the statutory
provisions that are addressed, identifies those areas when discretion
has been exercised, presents rationale for our decisions and, where
relevant, alternatives that were considered.
D. Impact on Beneficiaries
Overall, we believe these changes would improve beneficiary access
to reasonable and necessary services since services would now be more
appropriately valued. The payment changes would also affect beneficiary
liability. Any changes in aggregate beneficiary liability from a
particular work RVU change will be a function of the coinsurance (20
percent if applicable for the particular service after the beneficiary
has met the deductible) and the effect of the aggregate impact of the
work RVU changes on the calculation of the Medicare Part B premium rate
(generally, 25 percent of the aggregate payment change).
E. Accounting Statement
As required by OMB Circular A-4 (available at http://www.whitehouse.gov/omb/circulars/a004/a-4.pdf
), in Table 56, we have
prepared an accounting statement showing the classification of the
expenditures associated with the provisions of this proposed notice.
Expenditures are classified as transfers between Medicare
providers/suppliers (that is physicians, other practitioners medical
suppliers, and providers that receive payment under or based on the
PFS) and the Federal government. The -$40 million shown in Table 56
represents the net impact of an increase in FY 2007 payments for
mammography and a decrease in FY 2007 payments for physical therapy.
Table 56.--Accounting Statement--Classification of Estimated
Expenditures, from FY 2006 to FY 2007 (in millions)
------------------------------------------------------------------------
Category Transfers
------------------------------------------------------------------------
Annualized Monetized Transfers -$40
From Whom To Whom?................ Providers of physical therapy and
mammography services that are paid
based on Medicare Physician Fee
Schedule to the Federal government.
------------------------------------------------------------------------
In accordance with the provisions of Executive Order 12866, this
proposed notice was reviewed by the Office of Management and Budget.
(Catalog of Federal Domestic Assistance Program No. 93.773,
Medicare--Hospital Insurance; and Program No. 93.774, Medicare--
Supplementary Medical Insurance Program)
Dated: May 4, 2006.
Mark B. McClellan,
Administrator, Centers for Medicare & Medicaid Services.
Approved: June 9, 2006.
Michael O. Leavitt,
Secretary.
Note: These addenda will not appear in the Code of Federal
Regulations.
Addendum A: Explanation and Use of Addenda B
The addenda on the following pages provide various data
pertaining to the Medicare fee schedule for physicians' services
furnished in 2007. Addendum B contains the RVUs for work, non-
facility PE, facility PE, and malpractice expense, and other
information for all services included in the PFS.
[[Page 37257]]
In previous years, we have listed many services in Addendum B
that are not paid under the PFS. To avoid publishing as many pages
of codes for these services, we are not including clinical
laboratory codes and most alphanumeric codes (Healthcare Common
Procedure Coding System (HCPCS) codes not included in CPT) in
Addendum B.
Addendum B--2007 Relative Value Units and Related Information Used in
Determining Medicare Payments for 2007
This addendum contains the following information for each CPT
code and alphanumeric HCPCS code, except for: alphanumeric codes
beginning with B (enteral and parenteral therapy), E (durable
medical equipment), K (temporary codes for nonphysicians' services
or items), or L (orthotics); and codes for anesthesiology. The
Addendum B included in this proposed notice does not include codes
which are carrier priced since the RVUs for these services are set
at 0.00.
Please also note the following:
An ``NA'' in the ``Non-facility PE RVUs'' column of
Addendum B means that CMS has not developed a PE RVU in the non-
facility setting for the service because it is typically performed
in the hospital (for example, an open heart surgery is generally
performed in the hospital setting and not a physician's office).
Services that have an ``NA'' in the ``Facility PE
RVUs'' column of Addendum B are typically not paid using the PFS
when provided in a facility setting. These services (which include
``incident to'' services and the technical portion of diagnostic
tests) are generally paid under either the outpatient hospital
prospective payment system or bundled into the hospital inpatient
prospective payment system payment.
1. CPT/HCPCS code. This is the CPT or alphanumeric HCPCS number
for the service. Alphanumeric HCPCS codes are included at the end of
this addendum.
2. Modifier. A modifier is shown if there is a technical
component (modifier TC) and a professional component (PC) (modifier
-26) for the service. If there is a PC and a TC for the service,
Addendum B contains three entries for the code. A code for: the
global values (both professional and technical); modifier -26 (PC);
and, modifier TC. The global service is not designated by a
modifier, and physicians must bill using the code without a modifier
if the physician furnishes both the PC and the TC of the service.
Modifier-53 is shown for a discontinued procedure. There will be
RVUs for the code (CPT code 45378) with this modifier.
3. Status indicator. This indicator shows whether the CPT/HCPCS
code is in the PFS and whether it is separately payable if the
service is covered.
A = Active code. These codes are separately payable under the
PFS if covered. There will be RVUs for codes with this status. The
presence of an ``A'' indicator does not mean that Medicare has made
a national coverage determination regarding the service. Carriers
remain responsible for coverage decisions in the absence of a
national Medicare policy.
B = Bundled code. Payments for covered services are always
bundled into payment for other services not specified. If RVUs are
shown, they are not used for Medicare payment. If these services are
covered, payment for them is subsumed by the payment for the
services to which they are incident (an example is a telephone call
from a hospital nurse regarding care of a patient).
C = Carrier-priced code. Carriers will establish RVUs and
payment amounts for these services, generally on an individual case
basis following review of documentation, such as an operative
report.
D = Deleted/discontinued code. These codes are deleted effective
with the beginning of the CY and are always subject to a 90-day
grace period.
E = Excluded from the PFS by regulation. These codes are for
items and services that CMS excludes from payment under the PFS by
regulation. No RVUs are shown, and no payment may be made under the
PFS for these codes. Payment for them, when covered, continues under
reasonable charge procedures.
F = Deleted/discontinued codes. (Code not subject to a 90-day
grace period.) These codes are deleted effective with the beginning
of the CY and are never subject to a grace period. This indicator is
no longer effective as of January 1, 2006.
G = Code not valid for Medicare purposes. Medicare does not
recognize codes assigned this status. Medicare uses another code for
reporting of, and payment for, these services. (Codes subject to a
90-day grace period.) This indicator is no longer effective with the
2006 PFS as of January 1, 2006.
H = Deleted modifier. For 2000 and later years, either the TC or
PC component shown for the code has been deleted or the deleted
component is shown in the database with the H status indicator.
I = Not valid for Medicare purposes. Medicare uses another code
for the reporting of, and the payment for these services. (Codes not
subject to a 90-day grace period.)
N = Noncovered service. These codes are noncovered services.
Medicare payment may not be made for these codes. If RVUs are shown,
they are not used for Medicare payment.
P = Bundled or excluded code. There are no RVUs for these
services. No separate payment is made for them under the PFS.
--If the item or service is covered as incident to a physician's
service and is furnished on the same day as a physician's service,
payment for it is bundled into the payment for the physician's
service to which it is incident (an example is an elastic bandage
furnished by a physician incident to a physician's service).
--If the item or service is covered as other than incident to a
physician's service, it is excluded from the PFS (for example,
colostomy supplies) and is paid under the other payment provisions
of the Act.
R = Restricted coverage. Special coverage instructions apply. If
the service is covered and no RVUs are shown, it is carrier-priced.
T = There are RVUs for these services, but they are only paid if
there are no other services payable under the PFS billed on the same
date by the same provider. If any other services payable under the
PFS are billed on the same date by the same provider, these services
are bundled into the service(s) for which payment is made.
X = Exclusion by law. These codes represent an item or service
that is not within the definition of ``physicians' services'' for
PFS payment purposes. No RVUs are shown for these codes, and no
payment may be made under the PFS. (Examples are ambulance services
and clinical diagnostic laboratory services.)
4. Description of code. This is an abbreviated version of the
narrative description of the code.
5. Physician work RVUs. These are the RVUs for the physician
work for this service in 2007. The RVUs for codes with a 10- or 90-
day global period reflect the application of the RUC-recommended
values for the E/M services that are included as part of the global
period for the service. Codes that are not used for Medicare payment
are identified with a ``+.'' Note: The separate budget neutrality
adjustor is not reflected in these physician work RVUs.
6. Fully implemented non-facility practice expense RVUs. These
are the fully implemented resource-based PE RVUs for non-facility
settings.
7. Transitional Non-facility practice expense RVUs. These are
the 2007 resource-based PE RVUs for non-facility settings.
8. Fully implemented facility practice expense RVUs. These are
the fully implemented resource-based PE RVUs for facility settings.
9. Transitional facility practice expense RVUs. These are the
2007 resource-based PE RVUs for facility settings.
10. Malpractice expense RVUs. These are the RVUs for the
malpractice expense for the service for 2006.
11. Non-facility total. This is the sum of the work, fully
implemented non-facility PE, and malpractice expense RVUs.
12. Transitional non-facility total. This is the sum of the
work, 2007 transitional non-facility PE, and malpractice expense
RVUs.
13. Facility total. This is the sum of the work, fully
implemented facility PE, and malpractice expense RVUs.
14. Transitional facility total. This is the sum of the work,
2007 transitional facility PE, and malpractice expense RVUs.
15. Global period. This indicator shows the number of days in
the global period for the code (0, 10, or 90 days). An explanation
of the alpha codes follows:
MMM = Code describes a service furnished in uncomplicated
maternity cases including antepartum care, delivery, and postpartum
care. The usual global surgical concept does not apply. See the 1999
Physicians' CPT for specific definitions.
XXX = The global concept does not apply.
YYY = The global period is to be set by the carrier (for
example, unlisted surgery codes).
ZZZ = Code related to another service that is always included in
the global period of the other service. (Note: Physician work and PE
are associated with intra service time and in some instances the
post service time.)
[[Page 37258]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
0073T......... ........ A Radiation tx 0.00 13.15 16.84 NA NA 0.13 13.28 16.97 NA NA XXX
delivery, imrt.
10021......... ........ A Fna w/o image.. 1.27 2.11 2.15 0.35 0.49 0.10 3.48 3.52 1.72 1.86 XXX
10022......... ........ A Fna w/image.... 1.27 2.21 2.47 0.40 0.42 0.08 3.56 3.82 1.75 1.77 XXX
10040......... ........ A Acne surgery... 1.18 1.28 1.08 0.95 0.83 0.05 2.51 2.31 2.18 2.06 010
10060......... ........ A Drainage of 1.17 1.49 1.28 1.07 0.97 0.12 2.78 2.57 2.36 2.26 010
skin abscess.
10061......... ........ A Drainage of 2.40 2.05 1.89 1.49 1.50 0.26 4.71 4.55 4.15 4.16 010
skin abscess.
10080......... ........ A Drainage of 1.17 2.63 2.99 1.08 1.10 0.11 3.91 4.27 2.36 2.38 010
pilonidal cyst.
10081......... ........ A Drainage of 2.45 3.46 3.93 1.42 1.48 0.24 6.15 6.62 4.11 4.17 010
pilonidal cyst.
10120......... ........ A Remove foreign 1.22 2.09 2.16 0.93 0.96 0.12 3.43 3.50 2.27 2.30 010
body.
10121......... ........ A Remove foreign 2.69 3.49 3.51 1.62 1.75 0.33 6.51 6.53 4.64 4.77 010
body.
10140......... ........ A Drainage of 1.53 2.25 1.90 1.28 1.29 0.19 3.97 3.62 3.00 3.01 010
hematoma/fluid.
10160......... ........ A Puncture 1.20 1.85 1.66 1.07 1.08 0.14 3.19 3.00 2.41 2.42 010
drainage of
lesion.
10180......... ........ A Complex 2.25 3.28 3.06 1.81 1.95 0.35 5.88 5.66 4.41 4.55 010
drainage,
wound.
11000......... ........ A Debride 0.60 0.72 0.62 0.16 0.21 0.07 1.39 1.29 0.83 0.88 000
infected skin.
11001......... ........ A Debride 0.30 0.23 0.23 0.08 0.10 0.04 0.57 0.57 0.42 0.44 ZZZ
infected skin
add-on.
11004......... ........ A Debride 10.31 NA NA 3.00 3.68 0.67 NA NA 13.98 14.66 000
genitalia &
perineum.
11005......... ........ A Debride abdom 13.75 NA NA 3.98 5.18 0.96 NA NA 18.69 19.89 000
wall.
11006......... ........ A Debride genit/ 12.61 NA NA 3.55 4.53 1.28 NA NA 17.44 18.42 000
per/abdom wall.
11008......... ........ A Remove mesh 5.00 NA NA 1.33 1.86 0.61 NA NA 6.94 7.47 ZZZ
from abd wall.
11010......... ........ A Debride skin, 4.19 6.71 6.85 2.29 2.55 0.66 11.56 11.70 7.14 7.40 010
fx.
11011......... ........ A Debride skin/ 4.94 7.04 7.90 2.01 2.27 0.74 12.72 13.58 7.69 7.95 000
muscle, fx.
11012......... ........ A Debride skin/ 6.87 8.91 11.33 3.05 3.65 1.16 16.94 19.36 11.08 11.68 000
muscle/bone,
fx.
11040......... ........ A Debride skin, 0.50 0.68 0.56 0.16 0.20 0.06 1.24 1.12 0.72 0.76 000
partial.
11041......... ........ A Debride skin, 0.82 0.77 0.69 0.24 0.31 0.10 1.69 1.61 1.16 1.23 000
full.
11042......... ........ A Debride skin/ 1.12 1.04 0.99 0.33 0.41 0.13 2.29 2.24 1.58 1.66 000
tissue.
11043......... ........ A Debride tissue/ 3.00 3.61 3.45 2.68 2.62 0.32 6.93 6.77 6.00 5.94 010
muscle.
11044......... ........ A Debride tissue/ 4.05 4.91 4.57 3.64 3.73 0.43 9.39 9.05 8.12 8.21 010
muscle/bone.
11055......... ........ R Trim skin 0.43 0.81 0.62 0.11 0.16 0.05 1.29 1.10 0.59 0.64 000
lesion.
11056......... ........ R Trim skin 0.61 0.88 0.70 0.15 0.21 0.07 1.56 1.38 0.83 0.89 000
lesions, 2 to
4.
11057......... ........ R Trim skin 0.79 0.99 0.80 0.20 0.28 0.10 1.88 1.69 1.09 1.17 000
lesions, over
4.
11100......... ........ A Biopsy, skin 0.81 1.86 1.40 0.38 0.37 0.03 2.70 2.24 1.22 1.21 000
lesion.
11101......... ........ A Biopsy, skin 0.41 0.40 0.35 0.19 0.19 0.02 0.83 0.78 0.62 0.62 ZZZ
add-on.
11200......... ........ A Removal of skin 0.77 1.21 1.08 0.88 0.79 0.04 2.02 1.89 1.69 1.60 010
tags.
11201......... ........ A Remove skin 0.29 0.16 0.16 0.11 0.12 0.02 0.47 0.47 0.42 0.43 ZZZ
tags add-on.
11300......... ........ A Shave skin 0.51 1.18 1.04 0.20 0.21 0.03 1.72 1.58 0.74 0.75 000
lesion.
11301......... ........ A Shave skin 0.85 1.48 1.20 0.37 0.38 0.04 2.37 2.09 1.26 1.27 000
lesion.
11302......... ........ A Shave skin 1.05 1.75 1.41 0.47 0.46 0.05 2.85 2.51 1.57 1.56 000
lesion.
11303......... ........ A Shave skin 1.24 1.99 1.68 0.53 0.52 0.07 3.30 2.99 1.84 1.83 000
lesion.
11305......... ........ A Shave skin 0.67 1.05 0.90 0.20 0.25 0.07 1.79 1.64 0.94 0.99 000
lesion.
11306......... ........ A Shave skin 0.99 1.40 1.18 0.37 0.41 0.07 2.46 2.24 1.43 1.47 000
lesion.
11307......... ........ A Shave skin 1.14 1.68 1.39 0.46 0.48 0.07 2.89 2.60 1.67 1.69 000
lesion.
11308......... ........ A Shave skin 1.41 1.72 1.52 0.50 0.57 0.13 3.26 3.06 2.04 2.11 000
lesion.
11310......... ........ A Shave skin 0.73 1.37 1.18 0.31 0.32 0.04 2.14 1.95 1.08 1.09 000
lesion.
11311......... ........ A Shave skin 1.05 1.62 1.33 0.47 0.49 0.05 2.72 2.43 1.57 1.59 000
lesion.
11312......... ........ A Shave skin 1.20 1.89 1.54 0.55 0.55 0.06 3.15 2.80 1.81 1.81 000
lesion.
11313......... ........ A Shave skin 1.62 2.15 1.90 0.71 0.72 0.10 3.87 3.62 2.43 2.44 000
lesion.
11400......... ........ A Exc tr-ext 0.85 1.86 1.97 0.92 0.89 0.06 2.77 2.88 1.83 1.80 010
b9+marg 0.5 <
cm.
11401......... ........ A Exc tr-ext 1.23 2.15 2.08 1.12 1.05 0.10 3.48 3.41 2.45 2.38 010
b9+marg 0.6-1
cm.
11402......... ........ A Exc tr-ext 1.40 2.35 2.26 1.18 1.11 0.13 3.88 3.79 2.71 2.64 010
b9+marg 1.1-2
cm.
11403......... ........ A Exc tr-ext 1.79 2.52 2.43 1.54 1.38 0.17 4.48 4.39 3.50 3.34 010
b9+marg 2.1-3
cm.
11404......... ........ A Exc tr-ext 2.06 2.83 2.74 1.61 1.45 0.21 5.10 5.01 3.88 3.72 010
b9+marg 3.1-4
cm.
11406......... ........ A Exc tr-ext 3.45 3.37 3.15 1.94 1.72 0.32 7.14 6.92 5.71 5.49 010
b9+marg > 4.0
cm.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37259]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
11420......... ........ A Exc h-f-nk-sp 0.98 1.81 1.78 0.92 0.93 0.09 2.88 2.85 1.99 2.00 010
b9+marg 0.5 < .
11421......... ........ A Exc h-f-nk-sp 1.42 2.18 2.10 1.14 1.12 0.13 3.73 3.65 2.69 2.67 010
b9+marg 0.6-1.
11422......... ........ A Exc h-f-nk-sp 1.63 2.38 2.29 1.49 1.37 0.16 4.17 4.08 3.28 3.16 010
b9+marg 1.1-2.
11423......... ........ A Exc h-f-nk-sp 2.01 2.62 2.60 1.62 1.49 0.20 4.83 4.81 3.83 3.70 010
b9+marg 2.1-3.
11424......... ........ A Exc h-f-nk-sp 2.43 2.93 2.84 1.74 1.64 0.25 5.61 5.52 4.42 4.32 010
b9+marg 3.1-4.
11426......... ........ A Exc h-f-nk-sp 4.02 3.55 3.51 2.14 2.12 0.44 8.01 7.97 6.60 6.58 010
b9+marg > 4 cm.
11440......... ........ A Exc face-mm 1.00 1.98 2.15 1.29 1.31 0.08 3.06 3.23 2.37 2.39 010
b9+marg 0.5 <
cm.
11441......... ........ A Exc face-mm 1.48 2.34 2.34 1.52 1.50 0.13 3.95 3.95 3.13 3.11 010
b9+marg 0.6-1
cm.
11442......... ........ A Exc face-mm 1.72 2.58 2.56 1.61 1.58 0.16 4.46 4.44 3.49 3.46 010
b9+marg 1.1-2
cm.
11443......... ........ A Exc face-mm 2.29 2.81 2.89 1.79 1.81 0.22 5.32 5.40 4.30 4.32 010
b9+marg 2.1-3
cm.
11444......... ........ A Exc face-mm 3.14 3.21 3.41 2.03 2.15 0.30 6.65 6.85 5.47 5.59 010
b9+marg 3.1-4
cm.
11446......... ........ A Exc face-mm 4.73 3.86 4.00 2.47 2.70 0.43 9.02 9.16 7.63 7.86 010
b9+marg > 4 cm.
11450......... ........ A Removal, sweat 3.10 5.15 5.07 2.41 2.13 0.34 8.59 8.51 5.85 5.57 090
gland lesion.
11451......... ........ A Removal, sweat 4.31 6.14 6.50 2.77 2.61 0.53 10.98 11.34 7.61 7.45 090
gland lesion.
11462......... ........ A Removal, sweat 2.88 5.31 5.17 2.45 2.13 0.32 8.51 8.37 5.65 5.33 090
gland lesion.
11463......... ........ A Removal, sweat 4.31 6.58 6.78 2.94 2.75 0.54 11.43 11.63 7.79 7.60 090
gland lesion.
11470......... ........ A Removal, sweat 3.62 5.57 5.20 2.67 2.37 0.40 9.59 9.22 6.69 6.39 090
gland lesion.
11471......... ........ A Removal, sweat 4.77 6.42 6.65 2.95 2.82 0.58 11.77 12.00 8.30 8.17 090
gland lesion.
11600......... ........ A Exc tr-ext 1.56 2.61 2.63 1.01 0.98 0.10 4.27 4.29 2.67 2.64 010
mlg+marg 0.5 <
cm.
11601......... ........ A Exc tr-ext 2.00 3.27 2.85 1.35 1.25 0.12 5.39 4.97 3.47 3.37 010
mlg+marg 0.6-1
cm.
11602......... ........ A Exc tr-ext 2.20 3.65 3.04 1.52 1.33 0.12 5.97 5.36 3.84 3.65 010
mlg+marg 1.1-2
cm.
11603......... ........ A Exc tr-ext 2.75 3.85 3.27 1.69 1.42 0.16 6.76 6.18 4.60 4.33 010
mlg+marg 2.1-3
cm.
11604......... ........ A Exc tr-ext 3.10 4.15 3.57 1.76 1.48 0.20 7.45 6.87 5.06 4.78 010
mlg+marg 3.1-4
cm.
11606......... ........ A Exc tr-ext 4.95 5.28 4.37 2.27 1.87 0.36 10.59 9.68 7.58 7.18 010
mlg+marg > 4
cm.
11620......... ........ A Exc h-f-nk-sp 1.57 2.70 2.63 1.05 0.98 0.09 4.36 4.29 2.71 2.64 010
mlg+marg 0.5 < .
11621......... ........ A Exc h-f-nk-sp 2.01 3.32 2.86 1.38 1.28 0.12 5.45 4.99 3.51 3.41 010
mlg+marg 0.6-1.
11622......... ........ A Exc h-f-nk-sp 2.34 3.70 3.15 1.57 1.44 0.14 6.18 5.63 4.05 3.92 010
mlg+marg 1.1-2.
11623......... ........ A Exc h-f-nk-sp 3.04 3.92 3.49 1.78 1.63 0.20 7.16 6.73 5.02 4.87 010
mlg+marg 2.1-3.
11624......... ........ A Exc h-f-nk-sp 3.55 4.23 3.87 1.90 1.81 0.27 8.05 7.69 5.72 5.63 010
*mlg+marg 3.1-
4.
11626......... ........ A Exc h-f-nk-sp 4.54 4.88 4.70 2.26 2.37 0.45 9.87 9.69 7.25 7.36 010
mlg+mar > 4 cm.
11640......... ........ A Exc face-mm 1.60 2.89 2.72 1.14 1.12 0.11 4.60 4.43 2.85 2.83 010
malig+marg 0.5
< .
11641......... ........ A Exc face-mm 2.10 3.44 3.13 1.44 1.51 0.16 5.70 5.39 3.70 3.77 010
malig+marg 0.6-
1.
11642......... ........ A Exc face-mm 2.55 3.82 3.51 1.66 1.70 0.19 6.56 6.25 4.40 4.44 010
malig+marg 1.1-
2.
11643......... ........ A Exc face-mm 3.35 4.06 3.87 1.92 1.96 0.26 7.67 7.48 5.53 5.57 010
malig+marg 2.1-
3.
11644......... ........ A Exc face-mm 4.27 4.82 4.72 2.25 2.41 0.37 9.46 9.36 6.89 7.05 010
malig+marg 3.1-
4.
11646......... ........ A Exc face-mm 6.19 5.73 5.76 3.01 3.36 0.61 12.53 12.56 9.81 10.16 010
mlg+marg > 4
cm.
11719......... ........ R Trim nail(s)... 0.17 0.38 0.28 0.04 0.06 0.02 0.57 0.47 0.23 0.25 000
11720......... ........ A Debride nail, 1- 0.32 0.47 0.37 0.08 0.11 0.04 0.83 0.73 0.44 0.47 000
5.
11721......... ........ A Debride nail, 6 0.54 0.54 0.47 0.14 0.19 0.07 1.15 1.08 0.75 0.80 000
or more.
11730......... ........ A Removal of nail 1.13 1.34 1.11 0.29 0.40 0.14 2.61 2.38 1.56 1.67 000
plate.
11732......... ........ A Remove nail 0.57 0.54 0.47 0.14 0.20 0.07 1.18 1.11 0.78 0.84 ZZZ
plate, add-on.
11740......... ........ A Drain blood 0.37 0.80 0.61 0.43 0.37 0.04 1.21 1.02 0.84 0.78 000
from under
nail.
11750......... ........ A Removal of nail 2.36 2.94 2.36 1.86 1.79 0.22 5.52 4.94 4.44 4.37 010
bed.
11752......... ........ A Remove nail bed/ 3.42 4.07 3.27 2.77 2.94 0.35 7.84 7.04 6.54 6.71 010
finger tip.
11755......... ........ A Biopsy, nail 1.31 2.01 1.68 0.75 0.77 0.14 3.46 3.13 2.20 2.22 000
unit.
11760......... ........ A Repair of nail 1.58 3.41 2.83 1.42 1.70 0.21 5.20 4.62 3.21 3.49 010
bed.
11762......... ........ A Reconstruction 2.89 3.67 3.09 1.66 2.18 0.36 6.92 6.34 4.91 5.43 010
of nail bed.
11765......... ........ A Excision of 0.69 2.67 2.01 1.00 0.82 0.08 3.44 2.78 1.77 1.59 010
nail fold, toe.
11770......... ........ A Removal of 2.61 3.47 3.49 1.52 1.51 0.33 6.41 6.43 4.46 4.45 010
pilonidal
lesion.
11771......... ........ A Removal of 5.91 6.67 5.91 3.70 3.42 0.74 13.32 12.56 10.35 10.07 090
pilonidal
lesion.
11772......... ........ A Removal of 7.15 8.00 7.64 5.51 5.19 0.89 16.04 15.68 13.55 13.23 090
pilonidal
lesion.
11900......... ........ A Injection into 0.52 0.90 0.71 0.24 0.22 0.02 1.44 1.25 0.78 0.76 000
skin lesions.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37260]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
11901......... ........ A Added skin 0.80 1.00 0.75 0.38 0.36 0.03 1.83 1.58 1.21 1.19 000
lesions
injection.
11920......... ........ R Correct skin 1.61 2.37 3.38 1.10 1.09 0.24 4.22 5.23 2.95 2.94 000
color defects.
11921......... ........ R Correct skin 1.93 2.63 3.64 1.24 1.26 0.29 4.85 5.86 3.46 3.48 000
color defects.
11922......... ........ R Correct skin 0.49 0.92 1.09 0.22 0.24 0.07 1.48 1.65 0.78 0.80 ZZZ
color defects.
11950......... ........ R Therapy for 0.84 0.86 1.07 0.35 0.38 0.06 1.76 1.97 1.25 1.28 000
contour
defects.
11951......... ........ R Therapy for 1.19 1.17 1.41 0.52 0.51 0.11 2.47 2.71 1.82 1.81 000
contour
defects.
11952......... ........ R Therapy for 1.69 1.69 1.82 0.79 0.71 0.16 3.54 3.67 2.64 2.56 000
contour
defects.
11954......... ........ R Therapy for 1.85 1.78 2.28 0.77 0.87 0.25 3.88 4.38 2.87 2.97 000
contour
defects.
11960......... ........ A Insert tissue 10.85 NA NA 10.40 10.42 1.31 NA NA 22.56 22.58 090
expander(s).
11970......... ........ A Replace tissue 7.80 NA NA 5.94 6.10 1.05 NA NA 14.79 14.95 090
expander.
11971......... ........ A Remove tissue 3.13 7.33 8.69 3.95 3.84 0.32 10.78 12.14 7.40 7.29 090
expander(s).
11975......... ........ N Insert 1.48 1.53 1.45 0.33 0.51 0.17 3.18 3.10 1.98 2.16 XXX
contraceptive
cap.
11976......... ........ R Removal of 1.78 1.68 1.71 0.45 0.62 0.21 3.67 3.70 2.44 2.61 000
contraceptive
cap.
11977......... ........ N Removal/ 3.30 1.96 2.20 0.74 1.13 0.37 5.63 5.87 4.41 4.80 XXX
reinsert
contra cap.
11980......... ........ A Implant hormone 1.48 1.17 1.10 0.55 0.54 0.13 2.78 2.71 2.16 2.15 000
pellet(s).
11981......... ........ A Insert drug 1.48 1.96 1.77 0.61 0.66 0.12 3.56 3.37 2.21 2.26 XXX
implant device.
11982......... ........ A Remove drug 1.78 2.09 1.99 0.73 0.81 0.17 4.04 3.94 2.68 2.76 XXX
implant device.
11983......... ........ A Remove/insert 3.30 2.74 2.40 1.38 1.45 0.23 6.27 5.93 4.91 4.98 XXX
drug implant.
12001......... ........ A Repair 1.70 1.71 1.92 0.71 0.76 0.15 3.56 3.77 2.56 2.61 010
superficial
wound(s).
12002......... ........ A Repair 1.86 1.77 1.98 0.82 0.88 0.17 3.80 4.01 2.85 2.91 010
superficial
wound(s).
12004......... ........ A Repair 2.24 2.05 2.26 0.90 0.98 0.21 4.50 4.71 3.35 3.43 010
superficial
wound(s).
12005......... ........ A Repair 2.86 2.50 2.75 1.05 1.16 0.27 5.63 5.88 4.18 4.29 010
superficial
wound(s).
12006......... ........ A Repair 3.66 3.00 3.30 1.27 1.45 0.35 7.01 7.31 5.28 5.46 010
superficial
wound(s).
12007......... ........ A Repair 4.11 3.37 3.72 1.46 1.73 0.45 7.93 8.28 6.02 6.29 010
superficial
wound(s).
12011......... ........ A Repair 1.76 1.88 2.08 0.74 0.77 0.16 3.80 4.00 2.66 2.69 010
superficial
wound(s).
12013......... ........ A Repair 1.99 2.03 2.22 0.87 0.92 0.18 4.20 4.39 3.04 3.09 010
superficial
wound(s).
12014......... ........ A Repair 2.46 2.25 2.50 0.96 1.04 0.23 4.94 5.19 3.65 3.73 010
superficial
wound(s).
12015......... ........ A Repair 3.19 2.73 3.04 1.09 1.21 0.29 6.21 6.52 4.57 4.69 010
superficial
wound(s).
12016......... ........ A Repair 3.92 3.12 3.45 1.26 1.46 0.37 7.41 7.74 5.55 5.75 010
superficial
wound(s).
12017......... ........ A Repair 4.70 NA NA 1.45 1.79 0.47 NA NA 6.62 6.96 010
superficial
wound(s).
12018......... ........ A Repair 5.52 NA NA 1.94 2.18 0.64 NA NA 8.10 8.34 010
superficial
wound(s).
12020......... ........ A Closure of 2.62 3.73 3.81 1.76 1.89 0.30 6.65 6.73 4.68 4.81 010
split wound.
12021......... ........ A Closure of 1.84 1.84 1.83 1.32 1.39 0.24 3.92 3.91 3.40 3.47 010
split wound.
12031......... ........ A Layer closure 2.15 3.84 2.68 1.74 1.16 0.17 6.16 5.00 4.06 3.48 010
of wound(s).
12032......... ........ A Layer closure 2.47 5.13 4.17 2.23 1.91 0.16 7.76 6.80 4.86 4.54 010
of wound(s).
12034......... ........ A Layer closure 2.92 4.52 3.53 1.94 1.57 0.25 7.69 6.70 5.11 4.74 010
of wound(s).
12035......... ........ A Layer closure 3.42 5.23 5.22 2.07 2.14 0.39 9.04 9.03 5.88 5.95 010
of wound(s).
12036......... ........ A Layer closure 4.04 5.35 5.52 2.20 2.46 0.55 9.94 10.11 6.79 7.05 010
of wound(s).
12037......... ........ A Layer closure 4.66 5.90 6.06 2.57 2.87 0.66 11.22 11.38 7.89 8.19 010
of wound(s).
12041......... ........ A Layer closure 2.37 3.78 2.86 1.72 1.28 0.19 6.34 5.42 4.28 3.84 010
of wound(s).
12042......... ........ A Layer closure 2.74 4.40 3.55 2.06 1.61 0.17 7.31 6.46 4.97 4.52 010
of wound(s).
12044......... ........ A Layer closure 3.14 5.27 3.73 1.88 1.67 0.27 8.68 7.14 5.29 5.08 010
of wound(s).
12045......... ........ A Layer closure 3.63 5.04 5.22 2.04 2.23 0.41 9.08 9.26 6.08 6.27 010
of wound(s).
12046......... ........ A Layer closure 4.24 5.60 6.29 2.24 2.63 0.54 10.38 11.07 7.02 7.41 010
of wound(s).
12047......... ........ A Layer closure 4.64 6.11 6.30 2.47 2.94 0.58 11.33 11.52 7.69 8.16 010
of wound(s).
12051......... ........ A Layer closure 2.47 4.03 3.47 1.87 1.56 0.20 6.70 6.14 4.54 4.23 010
of wound(s).
12052......... ........ A Layer closure 2.77 4.34 3.51 2.06 1.59 0.17 7.28 6.45 5.00 4.53 010
of wound(s).
12053......... ........ A Layer closure 3.12 5.26 3.75 2.06 1.66 0.23 8.61 7.10 5.41 5.01 010
of wound(s).
12054......... ........ A Layer closure 3.45 5.31 4.01 2.00 1.72 0.30 9.06 7.76 5.75 5.47 010
of wound(s).
12055......... ........ A Layer closure 4.42 5.98 4.86 2.08 2.12 0.45 10.85 9.73 6.95 6.99 010
of wound(s).
12056......... ........ A Layer closure 5.23 6.15 6.62 2.34 2.88 0.59 11.97 12.44 8.16 8.70 010
of wound(s).
12057......... ........ A Layer closure 5.95 7.34 6.45 2.74 3.51 0.56 13.85 12.96 9.25 10.02 010
of wound(s).
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37261]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
13100......... ........ A Repair of wound 3.12 4.34 4.13 2.40 2.33 0.26 7.72 7.51 5.78 5.71 010
or lesion.
13101......... ........ A Repair of wound 3.91 5.85 4.97 2.91 2.75 0.26 10.02 9.14 7.08 6.92 010
or lesion.
13102......... ........ A Repair wound/ 1.24 1.33 1.21 0.52 0.56 0.13 2.70 2.58 1.89 1.93 ZZZ
lesion add-on.
13120......... ........ A Repair of wound 3.30 4.48 4.23 2.51 2.39 0.26 8.04 7.79 6.07 5.95 010
or lesion.
13121......... ........ A Repair of wound 4.32 6.13 5.18 3.10 2.88 0.25 10.70 9.75 7.67 7.45 010
or lesion.
13122......... ........ A Repair wound/ 1.44 1.36 1.47 0.57 0.62 0.15 2.95 3.06 2.16 2.21 ZZZ
lesion add-on.
13131......... ........ A Repair of wound 3.78 4.90 4.50 2.80 2.72 0.26 8.94 8.54 6.84 6.76 010
or lesion.
13132......... ........ A Repair of wound 6.44 7.73 6.37 4.83 4.34 0.32 14.49 13.13 11.59 11.10 010
or lesion.
13133......... ........ A Repair wound/ 2.19 1.82 1.70 0.94 1.01 0.18 4.19 4.07 3.31 3.38 ZZZ
lesion add-on.
13150......... ........ A Repair of wound 3.80 4.60 4.81 2.63 2.74 0.34 8.74 8.95 6.77 6.88 010
or lesion.
13151......... ........ A Repair of wound 4.44 5.39 4.96 3.13 3.15 0.31 10.14 9.71 7.88 7.90 010
or lesion.
13152......... ........ A Repair of wound 6.32 7.38 6.38 3.80 3.99 0.40 14.10 13.10 10.52 10.71 010
or lesion.
13153......... ........ A Repair wound/ 2.38 1.96 1.95 0.97 1.10 0.24 4.58 4.57 3.59 3.72 ZZZ
lesion add-on.
13160......... ........ A Late closure of 11.76 NA NA 6.98 7.13 1.54 NA NA 20.28 20.43 090
wound.
14000......... ........ A Skin tissue 6.75 8.78 8.10 5.91 5.59 0.59 16.12 15.44 13.25 12.93 090
rearrangement.
14001......... ........ A Skin tissue 9.52 10.90 9.81 7.40 7.17 0.82 21.24 20.15 17.74 17.51 090
rearrangement.
14020......... ........ A Skin tissue 7.58 9.80 8.92 6.70 6.59 0.64 18.02 17.14 14.92 14.81 090
rearrangement.
14021......... ........ A Skin tissue 11.10 12.18 10.55 8.43 8.33 0.81 24.09 22.46 20.34 20.24 090
rearrangement.
14040......... ........ A Skin tissue 8.36 10.23 9.18 7.06 7.18 0.62 19.21 18.16 16.04 16.16 090
rearrangement.
14041......... ........ A Skin tissue 12.59 13.27 11.28 9.10 8.80 0.73 26.59 24.60 22.42 22.12 090
rearrangement.
14060......... ........ A Skin tissue 8.99 9.94 9.09 7.47 7.46 0.68 19.61 18.76 17.14 17.13 090
rearrangement.
14061......... ........ A Skin tissue 13.57 14.52 12.35 9.92 9.63 0.76 28.85 26.68 24.25 23.96 090
rearrangement.
14300......... ........ A Skin tissue 13.16 13.25 11.68 9.22 9.21 1.16 27.57 26.00 23.54 23.53 090
rearrangement.
14350......... ........ A Skin tissue 10.72 NA NA 6.78 7.07 1.34 NA NA 18.84 19.13 090
rearrangement.
15000......... ........ A Wound prep, 1st 3.99 4.19 3.90 1.70 2.07 0.54 8.72 8.43 6.23 6.60 000
100 sq cm.
15001......... ........ A Wound prep, 1.00 0.55 1.15 0.34 0.39 0.14 1.69 2.29 1.48 1.53 ZZZ
addl 100 sq cm.
15040......... ........ A Harvest 2.00 3.82 4.38 1.01 1.10 0.24 6.06 6.62 3.25 3.34 000
cultured skin
graft.
15050......... ........ A Skin pinch 5.29 7.58 7.09 4.97 5.08 0.57 13.44 12.95 10.83 10.94 090
graft.
15100......... ........ A Skin splt grft, 9.66 10.25 12.03 7.16 7.67 1.28 21.19 22.97 18.10 18.61 090
trnk/arm/leg.
15101......... ........ A Skin splt grft 1.72 2.48 3.43 0.85 1.09 0.24 4.44 5.39 2.81 3.05 ZZZ
t/a/l, add-on.
15110......... ........ A Epidrm autogrft 10.82 8.81 10.23 6.40 6.87 1.31 20.94 22.36 18.53 19.00 090
trnk/arm/leg.
15111......... ........ A Epidrm autogrft 1.85 0.87 1.19 0.63 0.75 0.26 2.98 3.30 2.74 2.86 ZZZ
t/a/l add-on.
15115......... ........ A Epidrm a-grft 11.13 9.05 9.20 6.58 7.17 1.15 21.33 21.48 18.86 19.45 090
face/nck/hf/g.
15116......... ........ A Epidrm a-grft f/ 2.50 1.20 1.49 0.86 1.06 0.33 4.03 4.32 3.69 3.89 ZZZ
n/hf/g addl.
15120......... ........ A Skn splt a-grft 10.88 11.06 10.83 7.22 7.66 1.16 23.10 22.87 19.26 19.70 090
fac/nck/hf/g.
15121......... ........ A Skn splt a-grft 2.67 3.42 4.24 1.30 1.71 0.36 6.45 7.27 4.33 4.74 ZZZ
f/n/hf/g add.
15130......... ........ A Derm autograft, 7.33 7.94 9.40 5.56 6.16 0.97 16.24 17.70 13.86 14.46 090
trnk/arm/leg.
15131......... ........ A Derm autograft 1.50 0.68 0.97 0.51 0.61 0.21 2.39 2.68 2.22 2.32 ZZZ
t/a/l add-on.
15135......... ........ A Derm autograft 10.83 9.30 9.75 6.89 7.84 1.23 21.36 21.81 18.95 19.90 090
face/nck/hf/g.
15136......... ........ A Derm autograft, 1.50 0.66 0.83 0.52 0.63 0.20 2.36 2.53 2.22 2.33 ZZZ
f/n/hf/g add.
15150......... ........ A Cult epiderm 9.24 7.12 8.14 5.83 6.30 1.14 17.50 18.52 16.21 16.68 090
grft t/arm/leg.
15151......... ........ A Cult epiderm 2.00 0.88 1.20 0.68 0.81 0.28 3.16 3.48 2.96 3.09 ZZZ
grft t/a/l
addl.
15152......... ........ A Cult epiderm 2.50 1.05 1.43 0.85 1.01 0.35 3.90 4.28 3.70 3.86 ZZZ
graft t/a/l +%.
15155......... ........ A Cult epiderm 9.99 7.51 7.76 6.17 6.78 1.05 18.55 18.80 17.21 17.82 090
graft, f/n/hf/
g.
15156......... ........ A Cult epidrm 2.75 1.16 1.46 0.95 1.17 0.36 4.27 4.57 4.06 4.28 ZZZ
grft f/n/hfg
add.
15157......... ........ A Cult epiderm 3.00 1.34 1.67 1.04 1.27 0.39 4.73 5.06 4.43 4.66 ZZZ
grft f/n/hfg
+%.
15170......... ........ A Acell graft 5.99 3.60 3.78 2.31 2.36 0.55 10.14 10.32 8.85 8.90 090
trunk/arms/
legs.
15171......... ........ A Acell graft t/ 1.55 0.63 0.67 0.50 0.59 0.19 2.37 2.41 2.24 2.33 ZZZ
arm/leg add-on.
15175......... ........ A Acellular 7.99 5.17 5.37 3.68 3.93 0.82 13.98 14.18 12.49 12.74 090
graft, f/n/hf/
g.
15176......... ........ A Acell graft, f/ 2.45 1.05 1.10 0.79 0.94 0.29 3.79 3.84 3.53 3.68 ZZZ
n/hf/g add-on.
15200......... ........ A Skin full 8.89 9.76 9.51 6.22 6.22 0.98 19.63 19.38 16.09 16.09 090
graft, trunk.
15201......... ........ A Skin full graft 1.32 2.08 2.45 0.55 0.60 0.19 3.59 3.96 2.06 2.11 ZZZ
trunk add-on.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37262]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
15220......... ........ A Skin full graft 7.86 10.19 9.46 6.48 6.65 0.84 18.89 18.16 15.18 15.35 090
sclp/arm/leg.
15221......... ........ A Skin full graft 1.19 1.99 2.25 0.49 0.54 0.16 3.34 3.60 1.84 1.89 ZZZ
add-on.
15240......... ........ A Skin full grft 10.03 11.05 10.44 7.96 7.97 0.92 22.00 21.39 18.91 18.92 090
face/genit/hf.
15241......... ........ A Skin full graft 1.86 2.48 2.46 0.78 0.88 0.23 4.57 4.55 2.87 2.97 ZZZ
add-on.
15260......... ........ A Skin full graft 11.29 12.67 10.85 9.05 8.71 0.69 24.65 22.83 21.03 20.69 090
een & lips.
15261......... ........ A Skin full graft 2.23 2.89 2.75 1.11 1.33 0.21 5.33 5.19 3.55 3.77 ZZZ
add-on.
15300......... ........ A Apply 4.65 3.31 3.24 2.06 2.20 0.49 8.45 8.38 7.20 7.34 090
skinallogrft,
t/arm/lg.
15301......... ........ A Apply 1.00 0.47 0.47 0.33 0.38 0.14 1.61 1.61 1.47 1.52 ZZZ
sknallogrft t/
a/l addl.
15320......... ........ A Apply skin 5.36 3.69 3.65 2.27 2.47 0.58 9.63 9.59 8.21 8.41 090
allogrft f/n/
hf/g.
15321......... ........ A Aply 1.50 0.67 0.69 0.49 0.57 0.21 2.38 2.40 2.20 2.28 ZZZ
sknallogrft f/
n/hfg add.
15330......... ........ A Aply acell 3.99 3.10 3.18 1.86 2.14 0.49 7.58 7.66 6.34 6.62 090
alogrft t/arm/
leg.
15331......... ........ A Aply acell grft 1.00 0.45 0.46 0.33 0.38 0.14 1.59 1.60 1.47 1.52 ZZZ
t/a/l add-on.
15335......... ........ A Apply acell 4.50 3.35 3.45 2.02 2.34 0.55 8.40 8.50 7.07 7.39 090
graft, f/n/hf/
g.
15336......... ........ A Aply acell grft 1.43 0.70 0.69 0.47 0.55 0.20 2.33 2.32 2.10 2.18 ZZZ
f/n/hf/g add.
15340......... ........ A Apply cult skin 3.72 3.74 3.94 2.68 2.74 0.41 7.87 8.07 6.81 6.87 010
substitute.
15341......... ........ A Apply cult skin 0.50 0.72 0.64 0.16 0.19 0.06 1.28 1.20 0.72 0.75 ZZZ
sub add-on.
15360......... ........ A Apply cult derm 3.87 4.26 4.43 3.07 3.09 0.43 8.56 8.73 7.37 7.39 090
sub, t/a/l.
15361......... ........ A Aply cult derm 1.15 0.56 0.58 0.37 0.44 0.14 1.85 1.87 1.66 1.73 ZZZ
sub t/a/l add.
15365......... ........ A Apply cult derm 4.15 4.30 4.50 3.14 3.19 0.46 8.91 9.11 7.75 7.80 090
sub f/n/hf/g.
15366......... ........ A Apply cult derm 1.45 0.67 0.69 0.47 0.55 0.17 2.29 2.31 2.09 2.17 ZZZ
f/hf/g add.
15400......... ........ A Apply skin 4.32 4.87 4.23 3.66 3.93 0.47 9.66 9.02 8.45 8.72 090
xenograft, t/a/
l.
15401......... ........ A Apply skn 1.00 1.01 1.68 0.33 0.41 0.14 2.15 2.82 1.47 1.55 ZZZ
xenogrft t/a/l
add.
15420......... ........ A Apply skin 4.83 5.01 4.85 3.82 3.81 0.52 10.36 10.20 9.17 9.16 090
xgraft, f/n/hf/
g.
15421......... ........ A Apply skn xgrft 1.50 1.18 1.29 0.50 0.59 0.21 2.89 3.00 2.21 2.30 ZZZ
f/n/hf/g add.
15430......... ........ A Apply acellular 5.75 6.95 6.93 6.37 6.57 0.66 13.36 13.34 12.78 12.98 090
xenograft.
15570......... ........ A Form skin 9.94 10.21 11.05 6.35 6.67 1.34 21.49 22.33 17.63 17.95 090
pedicle flap.
15572......... ........ A Form skin 9.88 9.61 9.54 6.51 6.48 1.20 20.69 20.62 17.59 17.56 090
pedicle flap.
15574......... ........ A Form skin 10.48 10.26 10.60 6.81 7.56 1.20 21.94 22.28 18.49 19.24 090
pedicle flap.
15576......... ........ A Form skin 9.18 9.42 9.69 6.32 6.76 0.87 19.47 19.74 16.37 16.81 090
pedicle flap.
15600......... ........ A Skin graft..... 1.91 5.21 7.02 2.67 2.97 0.27 7.39 9.20 4.85 5.15 090
15610......... ........ A Skin graft..... 2.42 5.49 4.90 2.99 3.32 0.35 8.26 7.67 5.76 6.09 090
15620......... ........ A Skin graft..... 3.56 6.26 7.42 3.74 3.85 0.35 10.17 11.33 7.65 7.76 090
15630......... ........ A Skin graft..... 3.89 6.86 7.01 4.16 4.16 0.34 11.09 11.24 8.39 8.39 090
15650......... ........ A Transfer skin 4.58 7.00 7.12 4.19 4.21 0.42 12.00 12.12 9.19 9.21 090
pedicle flap.
15732......... ........ A Muscle-skin 19.62 14.42 17.17 10.88 11.91 1.99 36.03 38.78 32.49 33.52 090
graft, head/
neck.
15734......... ........ A Muscle-skin 19.52 14.95 17.36 11.12 12.09 2.61 37.08 39.49 33.25 34.22 090
graft, trunk.
15736......... ........ A Muscle-skin 16.86 13.54 17.10 9.75 10.88 2.45 32.85 36.41 29.06 30.19 090
graft, arm.
15738......... ........ A Muscle-skin 18.86 13.82 16.97 10.22 11.37 2.65 35.33 38.48 31.73 32.88 090
graft, leg.
15740......... ........ A Island pedicle 11.47 13.20 10.92 9.13 8.49 0.63 25.30 23.02 21.23 20.59 090
flap graft.
15750......... ........ A Neurovascular 12.63 NA NA 8.53 8.94 1.42 NA NA 22.58 22.99 090
pedicle graft.
15756......... ........ A Free myo/skin 36.64 NA NA 17.98 19.96 4.61 NA NA 59.23 61.21 090
flap microvasc.
15757......... ........ A Free skin flap, 36.85 NA NA 16.45 20.35 3.89 NA NA 57.19 61.09 090
microvasc.
15758......... ........ A Free fascial 36.60 NA NA 16.06 20.24 4.23 NA NA 56.89 61.07 090
flap,
microvasc.
15760......... ........ A Composite skin 9.60 10.03 10.05 6.74 7.15 0.85 20.48 20.50 17.19 17.60 090
graft.
15770......... ........ A Derma-fat- 8.63 NA NA 6.43 6.63 1.05 NA NA 16.11 16.31 090
fascia graft.
15775......... ........ R Hair transplant 3.95 3.51 4.06 1.70 1.40 0.52 7.98 8.53 6.17 5.87 000
punch grafts.
15776......... ........ R Hair transplant 5.53 3.91 5.01 1.56 2.50 0.72 10.16 11.26 7.81 8.75 000
punch grafts.
15780......... ........ A Abrasion 8.40 11.63 11.57 6.71 7.88 0.67 20.70 20.64 15.78 16.95 090
treatment of
skin.
15781......... ........ A Abrasion 4.84 8.47 7.32 5.49 5.41 0.34 13.65 12.50 10.67 10.59 090
treatment of
skin.
15782......... ........ A Abrasion 4.31 9.52 9.79 5.47 6.30 0.34 14.17 14.44 10.12 10.95 090
treatment of
skin.
15783......... ........ A Abrasion 4.28 7.95 7.16 4.97 4.39 0.28 12.51 11.72 9.53 8.95 090
treatment of
skin.
15786......... ........ A Abrasion, 2.03 3.77 3.46 1.22 1.30 0.11 5.91 5.60 3.36 3.44 010
lesion, single.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37263]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
15787......... ........ A Abrasion, 0.33 0.82 1.02 0.10 0.15 0.04 1.19 1.39 0.47 0.52 ZZZ
lesions, add-
on.
15788......... ........ R Chemical peel, 2.09 8.47 7.17 3.67 3.24 0.11 10.67 9.37 5.87 5.44 090
face, epiderm.
15789......... ........ R Chemical peel, 4.91 9.11 8.36 5.63 5.02 0.20 14.22 13.47 10.74 10.13 090
face, dermal.
15792......... ........ R Chemical peel, 1.86 6.78 7.03 3.43 4.20 0.13 8.77 9.02 5.42 6.19 090
nonfacial.
15793......... ........ A Chemical peel, 3.73 5.47 6.09 3.22 4.10 0.19 9.39 10.01 7.14 8.02 090
nonfacial.
15819......... ........ A Plastic 10.37 NA NA 6.54 7.04 0.97 NA NA 17.88 18.38 090
surgery, neck.
15820......... ........ A Revision of 6.01 6.09 6.77 4.94 5.42 0.40 12.50 13.18 11.35 11.83 090
lower eyelid.
15821......... ........ A Revision of 6.58 6.32 7.11 5.08 5.57 0.45 13.35 14.14 12.11 12.60 090
lower eyelid.
15822......... ........ A Revision of 4.44 4.97 5.63 3.88 4.35 0.37 9.78 10.44 8.69 9.16 090
upper eyelid.
15823......... ........ A Revision of 8.04 7.14 7.69 5.91 6.32 0.50 15.68 16.23 14.45 14.86 090
upper eyelid.
15831......... ........ A Excise 13.56 NA NA 8.57 8.28 1.75 NA NA 23.88 23.59 090
excessive skin
tissue.
15832......... ........ A Excise 12.57 NA NA 8.11 8.30 1.66 NA NA 22.34 22.53 090
excessive skin
tissue.
15833......... ........ A Excise 11.62 NA NA 7.11 7.95 1.49 NA NA 20.22 21.06 090
excessive skin
tissue.
15834......... ........ A Excise 11.89 NA NA 7.63 7.69 1.61 NA NA 21.13 21.19 090
excessive skin
tissue.
15835......... ........ A Excise 12.71 NA NA 7.67 7.59 1.60 NA NA 21.98 21.90 090
excessive skin
tissue.
15836......... ........ A Excise 10.33 NA NA 6.78 6.80 1.34 NA NA 18.45 18.47 090
excessive skin
tissue.
15837......... ........ A Excise 9.29 8.63 8.59 5.65 6.96 1.18 19.10 19.06 16.12 17.43 090
excessive skin
tissue.
15838......... ........ A Excise 7.99 NA NA 4.79 5.76 0.58 NA NA 13.36 14.33 090
excessive skin
tissue.
15839......... ........ A Excise 10.24 9.21 8.94 6.05 6.32 1.22 20.67 20.40 17.51 17.78 090
excessive skin
tissue.
15840......... ........ A Graft for face 14.66 NA NA 8.37 9.59 1.32 NA NA 24.35 25.57 090
nerve palsy.
15841......... ........ A Graft for face 25.57 NA NA 12.70 14.45 2.54 NA NA 40.81 42.56 090
nerve palsy.
15842......... ........ A Flap for face 40.54 NA NA 20.48 22.36 4.93 NA NA 65.95 67.83 090
nerve palsy.
15845......... ........ A Skin and muscle 13.92 NA NA 8.43 9.11 0.81 NA NA 23.16 23.84 090
repair, face.
15850......... ........ B Removal of 0.78 1.20 1.47 0.18 0.27 0.05 2.03 2.30 1.01 1.10 XXX
sutures.
15851......... ........ A Removal of 0.86 1.32 1.59 0.23 0.29 0.06 2.24 2.51 1.15 1.21 000
sutures.
15852......... ........ A Dressing change 0.86 1.61 1.79 0.25 0.31 0.09 2.56 2.74 1.20 1.26 000
not for burn.
15860......... ........ A Test for blood 1.95 0.68 0.79 0.68 0.76 0.27 2.90 3.01 2.90 2.98 000
flow in graft.
15920......... ........ A Removal of tail 8.06 NA NA 5.74 5.61 1.04 NA NA 14.84 14.71 090
bone ulcer.
15922......... ........ A Removal of tail 10.13 NA NA 6.89 7.15 1.42 NA NA 18.44 18.70 090
bone ulcer.
15931......... ........ A Remove sacrum 9.89 NA NA 5.50 5.65 1.25 NA NA 16.64 16.79 090
pressure sore.
15933......... ........ A Remove sacrum 11.49 NA NA 7.27 7.72 1.52 NA NA 20.28 20.73 090
pressure sore.
15934......... ........ A Remove sacrum 13.45 NA NA 7.50 7.92 1.78 NA NA 22.73 23.15 090
pressure sore.
15935......... ........ A Remove sacrum 15.45 NA NA 9.93 10.25 2.09 NA NA 27.47 27.79 090
pressure sore.
15936......... ........ A Remove sacrum 12.96 NA NA 7.38 8.03 1.76 NA NA 22.10 22.75 090
pressure sore.
15937......... ........ A Remove sacrum 14.91 NA NA 8.81 9.59 2.06 NA NA 25.78 26.56 090
pressure sore.
15940......... ........ A Remove hip 10.05 NA NA 5.76 6.08 1.31 NA NA 17.12 17.44 090
pressure sore.
15941......... ........ A Remove hip 12.13 NA NA 8.37 9.20 1.66 NA NA 22.16 22.99 090
pressure sore.
15944......... ........ A Remove hip 12.16 NA NA 8.10 8.49 1.65 NA NA 21.91 22.30 090
pressure sore.
15945......... ........ A Remove hip 13.45 NA NA 8.99 9.50 1.84 NA NA 24.28 24.79 090
pressure sore.
15946......... ........ A Remove hip 23.72 NA NA 13.66 14.22 3.16 NA NA 40.54 41.10 090
pressure sore.
15950......... ........ A Remove thigh 7.83 NA NA 5.33 5.41 1.04 NA NA 14.20 14.28 090
pressure sore.
15951......... ........ A Remove thigh 11.30 NA NA 7.84 7.87 1.49 NA NA 20.63 20.66 090
pressure sore.
15952......... ........ A Remove thigh 12.03 NA NA 7.66 7.74 1.60 NA NA 21.29 21.37 090
pressure sore.
15953......... ........ A Remove thigh 13.27 NA NA 8.91 8.99 1.79 NA NA 23.97 24.05 090
pressure sore.
15956......... ........ A Remove thigh 16.46 NA NA 9.51 10.48 2.21 NA NA 28.18 29.15 090
pressure sore.
15958......... ........ A Remove thigh 16.42 NA NA 10.13 10.84 2.25 NA NA 28.80 29.51 090
pressure sore.
16000......... ........ A Initial 0.89 0.72 0.83 0.23 0.25 0.08 1.69 1.80 1.20 1.22 000
treatment of
burn(s).
16020......... ........ A Dress/debrid p- 0.80 1.10 1.24 0.55 0.57 0.08 1.98 2.12 1.43 1.45 000
thick burn, s.
16025......... ........ A Dress/debrid p- 1.85 1.59 1.73 0.87 0.94 0.19 3.63 3.77 2.91 2.98 000
thick burn, m.
16030......... ........ A Dress/debrid p- 2.08 1.95 2.12 0.94 1.08 0.24 4.27 4.44 3.26 3.40 000
thick burn, l.
16035......... ........ A Incision of 3.74 NA NA 1.23 1.49 0.46 NA NA 5.43 5.69 090
burn scab,
initi.
16036......... ........ A Escharotomy; 1.50 NA NA 0.47 0.57 0.20 NA NA 2.17 2.27 ZZZ
addIl incision.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37264]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
17000......... ........ A Destroy benign/ 0.60 1.38 1.07 0.72 0.59 0.03 2.01 1.70 1.35 1.22 010
premlg lesion.
17003......... ........ A Destroy 0.07 0.10 0.11 0.03 0.06 0.01 0.18 0.19 0.11 0.14 ZZZ
lesions, 2-14.
17004......... ........ A Destroy 1.58 1.94 2.22 1.32 1.52 0.11 3.63 3.91 3.01 3.21 010
lesions, 15 or
more.
17106......... ........ A Destruction of 4.58 4.58 4.60 3.19 3.30 0.35 9.51 9.53 8.12 8.23 090
skin lesions.
17107......... ........ A Destruction of 9.15 7.14 7.20 5.05 5.37 0.63 16.92 16.98 14.83 15.15 090
skin lesions.
17108......... ........ A Destruction of 13.18 9.25 9.28 6.69 7.43 0.54 22.97 23.00 20.41 21.15 090
skin lesions.
17110......... ........ A Destruct 0.65 1.74 1.65 0.85 0.74 0.05 2.44 2.35 1.55 1.44 010
lesion, 1-14.
17111......... ........ A Destruct 0.92 2.25 1.82 1.10 0.88 0.05 3.22 2.79 2.07 1.85 010
lesion, 15 or
more.
17250......... ........ A Chemical 0.50 1.31 1.24 0.38 0.35 0.06 1.87 1.80 0.94 0.91 000
cautery,
tissue.
17260......... ........ A Destruction of 0.91 1.39 1.31 0.69 0.68 0.04 2.34 2.26 1.64 1.63 010
skin lesions.
17261......... ........ A Destruction of 1.17 2.45 1.82 1.04 0.88 0.05 3.67 3.04 2.26 2.10 010
skin lesions.
17262......... ........ A Destruction of 1.58 2.79 2.12 1.24 1.08 0.06 4.43 3.76 2.88 2.72 010
skin lesions.
17263......... ........ A Destruction of 1.79 3.01 2.30 1.33 1.15 0.07 4.87 4.16 3.19 3.01 010
skin lesions.
17264......... ........ A Destruction of 1.94 3.22 2.48 1.40 1.19 0.08 5.24 4.50 3.42 3.21 010
skin lesions.
17266......... ........ A Destruction of 2.34 3.47 2.75 1.56 1.31 0.09 5.90 5.18 3.99 3.74 010
skin lesions.
17270......... ........ A Destruction of 1.32 2.40 1.88 1.07 0.92 0.05 3.77 3.25 2.44 2.29 010
skin lesions.
17271......... ........ A Destruction of 1.49 2.62 1.99 1.19 1.03 0.06 4.17 3.54 2.74 2.58 010
skin lesions.
17272......... ........ A Destruction of 1.77 2.92 2.23 1.33 1.17 0.07 4.76 4.07 3.17 3.01 010
skin lesions.
17273......... ........ A Destruction of 2.05 3.16 2.45 1.46 1.27 0.08 5.29 4.58 3.59 3.40 010
skin lesions.
17274......... ........ A Destruction of 2.59 3.56 2.82 1.71 1.51 0.10 6.25 5.51 4.40 4.20 010
skin lesions.
17276......... ........ A Destruction of 3.20 3.83 3.17 1.94 1.75 0.16 7.19 6.53 5.30 5.11 010
skin lesions.
17280......... ........ A Destruction of 1.17 2.32 1.79 1.01 0.86 0.05 3.54 3.01 2.23 2.08 010
skin lesions.
17281......... ........ A Destruction of 1.72 2.69 2.11 1.30 1.14 0.07 4.48 3.90 3.09 2.93 010
skin lesions.
17282......... ........ A Destruction of 2.04 3.09 2.39 1.46 1.30 0.08 5.21 4.51 3.58 3.42 010
skin lesions.
17283......... ........ A Destruction of 2.64 3.50 2.79 1.73 1.55 0.11 6.25 5.54 4.48 4.30 010
skin lesions.
17284......... ........ A Destruction of 3.21 3.92 3.18 1.99 1.82 0.13 7.26 6.52 5.33 5.16 010
skin lesions.
17286......... ........ A Destruction of 4.43 4.31 3.84 2.40 2.44 0.23 8.97 8.50 7.06 7.10 010
skin lesions.
17304......... ........ A 1 stage mohs, 7.59 11.81 9.15 3.65 3.59 0.30 19.70 17.04 11.54 11.48 000
up to 5 spec.
17305......... ........ A 2 stage mohs, 2.85 6.85 4.64 1.37 1.35 0.11 9.81 7.60 4.33 4.31 000
up to 5 spec.
17306......... ........ A 3 stage mohs, 2.85 7.09 4.71 1.36 1.35 0.11 10.05 7.67 4.32 4.31 000
up to 5 spec.
17307......... ........ A Mohs addl stage 2.85 6.84 4.39 1.37 1.36 0.11 9.80 7.35 4.33 4.32 000
up to 5 spec.
17310......... ........ A Mohs any stage 0.95 1.97 1.71 0.46 0.46 0.03 2.95 2.69 1.44 1.44 ZZZ
> 5 spec each.
17340......... ........ A Cryotherapy of 0.76 0.32 0.36 0.36 0.36 0.05 1.13 1.17 1.17 1.17 010
skin.
17360......... ........ A Skin peel 1.43 1.40 1.43 0.97 0.90 0.06 2.89 2.92 2.46 2.39 010
therapy.
19000......... ........ A Drainage of 0.84 1.96 1.98 0.26 0.30 0.08 2.88 2.90 1.18 1.22 000
breast lesion.
19001......... ........ A Drain breast 0.42 0.26 0.25 0.13 0.14 0.04 0.72 0.71 0.59 0.60 ZZZ
lesion add-on.
19020......... ........ A Incision of 3.68 6.64 6.42 3.02 2.77 0.45 10.77 10.55 7.15 6.90 090
breast lesion.
19030......... ........ A Injection for 1.53 2.76 2.84 0.53 0.51 0.09 4.38 4.46 2.15 2.13 000
breast x-ray.
19100......... ........ A Bx breast 1.27 2.09 2.09 0.33 0.40 0.16 3.52 3.52 1.76 1.83 000
percut w/o
image.
19101......... ........ A Biopsy of 3.18 4.34 4.47 1.76 1.88 0.39 7.91 8.04 5.33 5.45 010
breast, open.
19102......... ........ A Bx breast 2.00 3.58 3.78 0.66 0.66 0.14 5.72 5.92 2.80 2.80 000
percut w/image.
19103......... ........ A Bx breast 3.69 10.42 11.25 1.17 1.22 0.30 14.41 15.24 5.16 5.21 000
percut w/
device.
19110......... ........ A Nipple 4.29 6.41 5.96 3.25 2.97 0.57 11.27 10.82 8.11 7.83 090
exploration.
19112......... ........ A Excise breast 3.66 6.26 6.13 3.14 2.80 0.48 10.40 10.27 7.28 6.94 090
duct fistula.
19120......... ........ A Removal of 5.80 5.08 4.68 3.35 3.14 0.73 11.61 11.21 9.88 9.67 090
breast lesion.
19125......... ........ A Excision, 6.55 5.55 4.98 3.64 3.38 0.80 12.90 12.33 10.99 10.73 090
breast lesion.
19126......... ........ A Excision, addl 2.93 NA NA 0.74 0.94 0.38 NA NA 4.05 4.25 ZZZ
breast lesion.
19140......... ........ A Removal of 5.13 8.01 7.37 3.81 3.50 0.69 13.83 13.19 9.63 9.32 090
breast tissue.
19160......... ........ A Partial 5.98 NA NA 3.60 3.47 0.79 NA NA 10.37 10.24 090
mastectomy.
19162......... ........ A P-mastectomy w/ 13.81 NA NA 6.08 6.28 1.79 NA NA 21.68 21.88 090
ln removal.
19180......... ........ A Removal of 15.61 NA NA 7.01 5.53 1.18 NA NA 23.80 22.32 090
breast.
19182......... ........ A Removal of 7.72 NA NA 4.97 4.81 1.04 NA NA 13.73 13.57 090
breast.
19200......... ........ A Removal of 17.13 NA NA 8.11 8.01 1.92 NA NA 27.16 27.06 090
breast.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37265]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
19220......... ........ A Removal of 17.73 NA NA 8.58 8.33 2.07 NA NA 28.38 28.13 090
breast.
19240......... ........ A Removal of 17.83 NA NA 8.74 8.35 2.12 NA NA 28.69 28.30 090
breast.
19260......... ........ A Removal of 17.52 NA NA 10.28 10.96 2.13 NA NA 29.93 30.61 090
chest wall
lesion.
19271......... ........ A Revision of 21.72 NA NA 16.08 17.52 2.62 NA NA 40.42 41.86 090
chest wall.
19272......... ........ A Extensive chest 24.68 NA NA 17.30 18.56 2.99 NA NA 44.97 46.23 090
wall surgery.
19290......... ........ A Place needle 1.27 3.00 2.90 0.44 0.43 0.07 4.34 4.24 1.78 1.77 000
wire, breast.
19291......... ........ A Place needle 0.63 1.18 1.20 0.22 0.21 0.04 1.85 1.87 0.89 0.88 ZZZ
wire, breast.
19295......... ........ A Place breast 0.00 2.38 2.62 NA NA 0.01 2.39 2.63 NA NA ZZZ
clip, percut.
19296......... ........ A Place po breast 3.63 85.16 115.6 1.19 1.45 0.36 89.15 119.6 5.18 5.44 000
cath for rad.
19297......... ........ A Place breast 1.72 NA NA 0.46 0.60 0.17 NA NA 2.35 2.49 ZZZ
cath for rad.
19298......... ........ A Place breast 6.00 23.02 37.47 1.94 2.30 0.43 29.45 43.90 8.37 8.73 000
rad tube/caths.
19316......... ........ A Suspension of 10.92 NA NA 6.94 7.38 1.64 NA NA 19.50 19.94 090
breast.
19318......... ........ A Reduction of 15.85 NA NA 9.75 10.84 2.92 NA NA 28.52 29.61 090
large breast.
19324......... ........ A Enlarge breast. 6.59 NA NA 4.56 4.82 0.84 NA NA 11.99 12.25 090
19325......... ........ A Enlarge breast 8.44 NA NA 6.33 6.49 1.33 NA NA 16.10 16.26 090
with implant.
19328......... ........ A Removal of 6.29 NA NA 4.94 5.01 0.91 NA NA 12.14 12.21 090
breast implant.
19330......... ........ A Removal of 8.33 NA NA 5.96 6.03 1.26 NA NA 15.55 15.62 090
implant
material.
19340......... ........ A Immediate 6.32 NA NA 2.78 3.04 1.06 NA NA 10.16 10.42 ZZZ
breast
prosthesis.
19342......... ........ A Delayed breast 12.30 NA NA 8.68 8.88 1.83 NA NA 22.81 23.01 090
prosthesis.
19350......... ........ A Breast 8.91 9.75 12.85 6.46 7.01 1.41 20.07 23.17 16.78 17.33 090
reconstruction.
19355......... ........ A Correct 8.31 7.67 9.63 4.84 4.74 0.92 16.90 18.86 14.07 13.97 090
inverted
nipple(s).
19357......... ........ A Breast 20.33 NA NA 15.17 15.54 2.93 NA NA 38.43 38.80 090
reconstruction.
19361......... ........ A Breast 20.63 NA NA 12.06 12.37 2.92 NA NA 35.61 35.92 090
reconstruction.
19364......... ........ A Breast 42.30 NA NA 22.32 23.29 6.22 NA NA 70.84 71.81 090
reconstruction.
19366......... ........ A Breast 21.62 NA NA 9.92 11.19 3.24 NA NA 34.78 36.05 090
reconstruction.
19367......... ........ A Breast 26.51 NA NA 14.97 16.30 4.03 NA NA 45.51 46.84 090
reconstruction.
19368......... ........ A Breast 33.51 NA NA 17.75 18.67 5.52 NA NA 56.78 57.70 090
reconstruction.
19369......... ........ A Breast 30.92 NA NA 15.55 17.73 4.50 NA NA 50.97 53.15 090
reconstruction.
19370......... ........ A Surgery of 8.91 NA NA 6.71 6.87 1.29 NA NA 16.91 17.07 090
breast capsule.
19371......... ........ A Removal of 10.34 NA NA 7.57 7.77 1.62 NA NA 19.53 19.73 090
breast capsule.
19380......... ........ A Revise breast 10.13 NA NA 7.50 7.67 1.44 NA NA 19.07 19.24 090
reconstruction.
19396......... ........ A Design custom 2.17 4.46 1.93 1.21 1.05 0.30 6.93 4.40 3.68 3.52 000
breast implant.
20000......... ........ A Incision of 2.12 2.77 2.72 1.51 1.68 0.25 5.14 5.09 3.88 4.05 010
abscess.
20005......... ........ A Incision of 3.53 3.70 3.55 2.02 2.20 0.46 7.69 7.54 6.01 6.19 010
deep abscess.
20100......... ........ A Explore wound, 10.31 NA NA 3.56 4.24 1.21 NA NA 15.08 15.76 010
neck.
20101......... ........ A Explore wound, 3.22 6.46 6.07 1.50 1.59 0.44 10.12 9.73 5.16 5.25 010
chest.
20102......... ........ A Explore wound, 3.93 6.95 7.35 1.83 1.89 0.49 11.37 11.77 6.25 6.31 010
abdomen.
20103......... ........ A Explore wound, 5.29 7.63 8.36 2.68 3.22 0.75 13.67 14.40 8.72 9.26 010
extremity.
20150......... ........ A Excise 14.54 NA NA 7.57 7.18 2.03 NA NA 24.14 23.75 090
epiphyseal bar.
20200......... ........ A Muscle biopsy.. 1.46 3.16 3.07 0.70 0.74 0.23 4.85 4.76 2.39 2.43 000
20205......... ........ A Deep muscle 2.35 3.83 3.88 1.09 1.17 0.33 6.51 6.56 3.77 3.85 000
biopsy.
20206......... ........ A Needle biopsy, 0.99 5.45 6.25 0.57 0.62 0.07 6.51 7.31 1.63 1.68 000
muscle.
20220......... ........ A Bone biopsy, 1.27 2.81 4.13 0.68 0.76 0.08 4.16 5.48 2.03 2.11 000
trocar/needle.
20225......... ........ A Bone biopsy, 1.87 13.50 21.77 1.07 1.12 0.22 15.59 23.86 3.16 3.21 000
trocar/needle.
20240......... ........ A Bone biopsy, 3.23 NA NA 2.06 2.44 0.44 NA NA 5.73 6.11 010
excisional.
20245......... ........ A Bone biopsy, 8.71 NA NA 5.70 6.37 1.31 NA NA 15.72 16.39 010
excisional.
20250......... ........ A Open bone 5.14 NA NA 3.67 3.55 1.02 NA NA 9.83 9.71 010
biopsy.
20251......... ........ A Open bone 5.67 NA NA 3.84 4.09 1.15 NA NA 10.66 10.91 010
biopsy.
20500......... ........ A Injection of 1.23 1.33 2.04 0.87 1.37 0.12 2.68 3.39 2.22 2.72 010
sinus tract.
20501......... ........ A Inject sinus 0.76 2.47 2.81 0.27 0.26 0.04 3.27 3.61 1.07 1.06 000
tract for x-
ray.
20520......... ........ A Removal of 1.85 2.57 2.83 1.42 1.68 0.21 4.63 4.89 3.48 3.74 010
foreign body.
20525......... ........ A Removal of 3.49 7.02 8.63 2.16 2.51 0.51 11.02 12.63 6.16 6.51 010
foreign body.
20526......... ........ A Ther injection, 0.94 0.80 0.93 0.40 0.49 0.13 1.87 2.00 1.47 1.56 000
carp tunnel.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ CPT codes and descriptors only are copyright 2005 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.
\2\ Copyright 2005 American Dental Association. All rights reserved.
\3\ Indicates RVUs are not used for Medicare payment.
[[Page 37266]]
Addendum B.--Relative Value Units (RVUs) and Related Information Used In Determining Medicare Payments for 2007--Continued
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Fully Fully
Physician implemented Year 2007 Fully Year 2007 Mal- implemented Year 2007 Fully Year 2007
CPT \1\ HCPCS Mod Status Description work RVUs non- transitional implemented transitional practice non- transitional implemented transitional Global
\2\ \3\ facility PE non-facility facility PE facility PE RVUs facility non-facility facility facility
RVUs PE RVUs RVUs RVUs total total total total
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
20550......... ........ A Inj tendon 0.75 0.62 0.69 0.28 0.24 0.09 1.46 1.53 1.12 1.08 000
sheath/
ligament.
20551......... ........ A Inj tendon 0.75 0.63 0.67 0.28 0.32 0.08 1.46 1.50 1.11 1.15 000
origin/
insertion.
20552......... ........ A Inj trigger 0.66 0.58 0.69 0.24 0.21 0.05 1.29 1.40 0.95 0.92 000
point, 1/2
muscl.
20553......... ........ A Inject trigger 0.75 0.64 0.78 0.26 0.23 0.04 1.43 1.57 1.05 1.02 000
points, =/> 3.
20600......... ........ A Drain/inject, 0.66 0.66 0.65 0.31 0.34 0.08 1.40 1.39 1.05 1.08 000
joint/bursa.
20605......... ........ A Drain/inject, 0.68 0.73 0.75 0.32 0.35 0.08 1.49 1.51 1.08 1.11 000
joint/bursa.
20610......... ........ A Drain/inject, 0.79 1.06 0.98 0.39 0.41 0.11 1.96 1.88 1.29 1.31 000
joint/bursa.
20612......... ........ A Aspirate/inj 0.70 0.69 0.71 0.31 0.35 0.10 1.49 1.51 1.11 1.15 000
ganglion cyst.
20615......... ........ A Treatment of 2.28 2.69 3.31 1.39 1.74 0.20 5.17 5.79 3.87 4.22 010
bone cyst.
20650......... ........ A Insert and 2.23 2.47 2.40 1.45 1.53 0.31 5.01 4.94 3.99 4.07 010
remove bone
pin.
20660......... ........ A Apply, rem 2.51 3.33 3.13 1.46 1.57 0.59 6.43 6.23 4.56 4.67 000
fixation
device.
20661......... ........ A Application of 5.06 NA NA 5.87 5.16 1.14 NA NA 12.07 11.36 090
head brace.
20662......... ........ A Application of 6.18 NA NA 4.96 5.40 0.56 NA NA 11.70 12.14 090
pelvis brace.
20663......... ........ A Application of 5.54 NA NA 5.04 4.89 0.94 NA NA 11.52 11.37 090
thigh brace.
20664......... ........ A Halo brace 9.78 NA NA 7.92 7.28 1.74 NA NA 19.44 18.80 090
application.
20665......... ........ A Removal of 1.31 1.40 1.97 0.98 1.26 0.19 2.90 3.47 2.48 2.76 010
fixation
device.
20670......... ........ A Removal of 1.74 6.63 10.34 1.66 2.00 0.28 8.65 12.36 3.68 4.02 010
support
implant.
20680......... ........ A Removal of 5.86 8.09 8.63 4.02 3.80 0.56 14.51 15.05 10.44 10.22 090
support
implant.
20690......... ........ A Apply bone 3.63 NA NA 2.22 2.45 0.59 NA NA 6.44 6.67 090
fixation
device.
20692......... ........ A Apply bone 6.40 NA NA 3.20 3.64 1.05 NA NA 10.65 11.09 090
fixation
device.
20693......... ........ A Adjust bone 5.91 NA NA 4.45 5.21 0.98 NA NA 11.34 12.10 090
fixation
device.
20694......... ........ A Remove bone 4.15 5.29 6.69 3.50 3.91 0.71 10.15 11.55 8.36 8.77 090
fixation
device.
20802......... ........ A Replantation, 42.16 NA NA 12.96 19.00 3.81 NA NA 58.93 64.97 090
arm, complete.
20805......... ........ A Replant 51.00 NA NA 23.26 31.62 4.84 NA NA 79.10 87.46 090
forearm,
complete.
20808......... ........ A Replantation 62.63 NA NA 37.95 41.24 6.86 NA NA 107.4 110.7 090
hand, complete.
20816......... ........ A Replantation 31.64 NA NA 24.04 34.44 4.52 NA NA 60.20 70.60 090
digit,
complete.
20822......... ........ A Replantation 26.30 NA NA 21.95 31.51 4.18 NA NA 52.43 61.99 090
digit,
complete.
20824......... ........ A Replantation 31.64 NA NA 25.31 33.82 4.61 NA NA 61.56 70.07 090
thumb,
complete.
20827......... ........ A Replantation 27.12 NA NA 23.48 33.31 3.66 NA NA 54.26 64.09 090
thumb,
complete.
20838......... ........ A Replantation 42.42 NA NA 13.13 20.04 1.12 NA NA 56.67 63.58 090
foot, complete.
20900......... ........ A Removal of bone 5.69 9.21 8.64 4.87 5.49 0.94 15.84 15.27 11.50 12.12 090
for graft.
20902......... ........ A Removal of bone 7.90 NA NA 5.74 6.61 1.30 NA NA 14.94 15.81 090
for graft.
20910......... ........ A Remove 5.33 NA NA 4.54 5.04 0.71 NA NA 10.58 11.08 090
cartilage for
graft.
20912......