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2006 proposed fee schedule - American Society of Clinical Oncology

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accurate for calculating direct costs than the SMS or<br />

supplementary survey data, we are concerned that there is<br />

such a discrepancy between the refined direct cost inputs<br />

and a recent survey. We will want to discuss this issue<br />

with both the specialty and the RUC to ensure that the<br />

refined CPEP/RUC data accurately reflect the typical<br />

resources needed for these services. However, as we<br />

indicated above, independent laboratories receive only<br />

approximately 20 percent <strong>of</strong> their total Medicare revenues<br />

from PFS services, and there should not be significant<br />

impact on other specialties from this increase for<br />

independent laboratory services.<br />

328<br />

As discussed in section II.C. <strong>of</strong> this <strong>proposed</strong> rule, we<br />

are proposing technical changes to the calculation <strong>of</strong> the<br />

malpractice RVUs. We are proposing to remove the<br />

malpractice data for specialties that occur less than 5<br />

percent <strong>of</strong> the time in our data for a procedure code. In<br />

addition, the RUC practice liability workgroup has written<br />

to us recommending several changes to the crosswalks used to<br />

assign risk factors to specialties for which we did not have<br />

data otherwise. We are proposing to accept these<br />

recommendations, and, as also recommended, we are proposing<br />

to use the lowest risk factor <strong>of</strong> 1.00 for specialties such<br />

as clinical psychology, licensed clinical social work,<br />

chiropractors, and physical therapists. We are also

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