2006 proposed fee schedule - American Society of Clinical Oncology

2006 proposed fee schedule - American Society of Clinical Oncology 2006 proposed fee schedule - American Society of Clinical Oncology

19.02.2013 Views

Therefore, we propose assigning these specialties a risk 100 factor of 1.00. We invite comment from representatives of the affected specialties and others regarding the appropriateness of this proposal, as well as other specialty crosswalks and suggestions for reliable sources of actual malpractice premium data for nonphysician groups. The RUC PLI Workgroup also felt that a number of professions that were assigned to the average for all physicians risk factor should be removed from the calculation of malpractice RVUs altogether. The PLI Workgroup believes that it would be more appropriate to exclude data from the following professions: certified clinical nurse specialist (CNS), clinical laboratory, multispecialty clinic or group practice, NP, physician assistant (PA), and physiological laboratory (independent). In calculating the malpractice RVUs applicable for 2005, 34 Medicare specialties were excluded from the calculation because they could not be otherwise assigned or crosswalked. The RUC recommends the above specialties and professions be similarly excluded. We agree and propose to establish malpractice RVUs based upon the mix of specialties exclusive of the above specialties and professions. The PLI Workgroup also made the following recommendations that we are not accepting: certified registered nurse anesthetists (CRNAs) should be crosswalked

to anesthesiology which is 2.84 rather than to the “all physicians” which is 3.04; colorectal surgeons should be 101 crosswalked to general surgery (the current risk factor is based on actual data); and gynecologists and oncologists (currently 5.63) should be crosswalked to surgical oncology (currently 6.13). We believe the current crosswalks we are using for these specialties appropriately reflect the types of services they provide. However, we would welcome comments on these proposals as well. 3. Cardiac Catheterization and Angioplasty Exception In response to a comment received on our proposed methodology at the time, in the November 2, 1999 final rule (64 FR 59384), we applied surgical risk factors to the following cardiology catheterization and angioplasty codes: 92980 to 92998 and 93501 to 93536. This exception was established because these procedures are quite invasive and more akin to surgical than nonsurgical procedures. In the November 15, 2004 final rule (69 FR 66275), we discussed changes in those codes that would fall under the exception. Based on a recommendation by the RUC, we revised the list of codes to which this exception applies. The RUC’s PLI Workgroup requests that we correct a clerical error made by the RUC in identifying those codes that would fall under the exception. We agree with the RUC PLI Workgroup recommendation and propose that the following CPT

Therefore, we propose assigning these specialties a risk<br />

100<br />

factor <strong>of</strong> 1.00. We invite comment from representatives <strong>of</strong><br />

the affected specialties and others regarding the<br />

appropriateness <strong>of</strong> this proposal, as well as other specialty<br />

crosswalks and suggestions for reliable sources <strong>of</strong> actual<br />

malpractice premium data for nonphysician groups.<br />

The RUC PLI Workgroup also felt that a number <strong>of</strong><br />

pr<strong>of</strong>essions that were assigned to the average for all<br />

physicians risk factor should be removed from the<br />

calculation <strong>of</strong> malpractice RVUs altogether. The PLI<br />

Workgroup believes that it would be more appropriate to<br />

exclude data from the following pr<strong>of</strong>essions: certified<br />

clinical nurse specialist (CNS), clinical laboratory,<br />

multispecialty clinic or group practice, NP, physician<br />

assistant (PA), and physiological laboratory (independent).<br />

In calculating the malpractice RVUs applicable for 2005, 34<br />

Medicare specialties were excluded from the calculation<br />

because they could not be otherwise assigned or crosswalked.<br />

The RUC recommends the above specialties and pr<strong>of</strong>essions be<br />

similarly excluded. We agree and propose to establish<br />

malpractice RVUs based upon the mix <strong>of</strong> specialties exclusive<br />

<strong>of</strong> the above specialties and pr<strong>of</strong>essions.<br />

The PLI Workgroup also made the following<br />

recommendations that we are not accepting: certified<br />

registered nurse anesthetists (CRNAs) should be crosswalked

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