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2006 proposed fee schedule - American Society of Clinical Oncology

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hour for these specialties. As noted in the preamble<br />

discussion regarding our proposal to change the PE<br />

methodology, the nonphysician work pool was created to<br />

protect codes without physician work components until<br />

325<br />

further refinement could occur. Removing these codes from<br />

the nonphysician work pool generally has a negative impact<br />

on these codes (although we note that we have consistently<br />

indicated this methodology was an interim approach until we<br />

had better data available). In addition, the limited number<br />

<strong>of</strong> codes remaining in the nonphysician work pool would also<br />

experience significant impacts. Eliminating the<br />

nonphysician work pool would generally negatively impact<br />

these codes remaining in the pool (for example, certain<br />

codes used by audiology and portable x-ray suppliers). We<br />

believe that much <strong>of</strong> this impact is due to the change in the<br />

scaling <strong>of</strong> the inputs when codes move from the nonphysician<br />

work pool to the individual specialty pool.<br />

We believe that, in addition to the increased accuracy<br />

and simplicity that result from using a "bottom-up" approach<br />

for direct costs, this <strong>proposed</strong> approach also helps mitigate<br />

some <strong>of</strong> the potentially inequitable redistribution <strong>of</strong><br />

practice expense RVUs resulting from the acceptance <strong>of</strong> new<br />

specialty-specific survey data. However, several <strong>of</strong> the<br />

impacts that are shown require further consideration.

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