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
Audiology is clearly negatively impacted when its 326 services are removed from the nonphysician work pool, though the impact is cut nearly in half when the "bottom-up" approach is used for the direct costs. This impact is in large part driven by the decrease in the PE RVUs for audiology CPT codes 92557, 92567 and 92588, which we believe may now be more appropriately priced in our proposal than they were in the nonphysician work pool that uses historic charge-based RVUs to determine the direct practice expense for a service. However, we would welcome discussions with audiologists regarding this impact, so that we can ensure that the relative costs are reflected appropriately. Despite submitting a supplementary survey that showed higher PE costs per hour, cardiology is shown to have an impact of -2.1 percent in the last column of Table 30. This is largely due to the decrease in direct PE for several high-volume services resulting from the adoption of the “bottom up” approach. For example, the RVUs for the complete electrocardiogram service, CPT code 93000, decline by 43 percent. The RVUs for multiple 3-D heart imaging, CPT Code 78465, decline by 32 percent. However, it should be noted that, if the new survey data had not been used to calculate indirect PE, cardiology would have had a significantly larger (11 percent) negative impact.
Both physical/occupational therapy and independent laboratory show significant positive impacts in the last 327 column of 6.0 and 28.0 percent, respectively. For therapy services, we had previously applied an adjustment that assigned all therapy services the therapy practice expense per hour, even when billed by specialties with higher costs. Under the top-down methodology, this adjustment was applied to both direct and indirect costs. However, under our proposed methodology, the practice expense per hour data would not be used to calculate direct expenses and this would eliminate the adjustment for direct practice expense costs. The total CPEP/RUC dollars for supplies and equipment for the services performed by independent laboratories are significantly higher than the aggregate dollars shown by the recent supplementary survey for these cost pools. Therefore, under the current top-down methodology, the CPEP/RUC dollars are scaled down to equal the survey dollars, and the practice expense RVUs are consequently reduced. Under our proposed methodology, the direct costs would no longer be scaled, resulting in higher practice expense RVUs for these services. (This also results in a positive 5.2 percent impact for pathologists, who also perform these services.) Although, as discussed above, we generally believe the refined CPEP/RUC data to be more
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Both physical/occupational therapy and independent<br />
laboratory show significant positive impacts in the last<br />
327<br />
column <strong>of</strong> 6.0 and 28.0 percent, respectively. For therapy<br />
services, we had previously applied an adjustment that<br />
assigned all therapy services the therapy practice expense<br />
per hour, even when billed by specialties with higher costs.<br />
Under the top-down methodology, this adjustment was applied<br />
to both direct and indirect costs. However, under our<br />
<strong>proposed</strong> methodology, the practice expense per hour data<br />
would not be used to calculate direct expenses and this<br />
would eliminate the adjustment for direct practice expense<br />
costs.<br />
The total CPEP/RUC dollars for supplies and equipment<br />
for the services performed by independent laboratories are<br />
significantly higher than the aggregate dollars shown by the<br />
recent supplementary survey for these cost pools.<br />
Therefore, under the current top-down methodology, the<br />
CPEP/RUC dollars are scaled down to equal the survey<br />
dollars, and the practice expense RVUs are consequently<br />
reduced. Under our <strong>proposed</strong> methodology, the direct costs<br />
would no longer be scaled, resulting in higher practice<br />
expense RVUs for these services. (This also results in a<br />
positive 5.2 percent impact for pathologists, who also<br />
perform these services.) Although, as discussed above, we<br />
generally believe the refined CPEP/RUC data to be more