2006 proposed fee schedule - American Society of Clinical Oncology

We believe that we have consistently made a good faith
effort to ensure fairness in our PE payment system by using
the best data available at any one time. The change from
the originally proposed “bottom-up” to the “top-down”
methodology came about because of a concern 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. The adoption of the top-down approach
necessitated the creation of the nonphysician work pool.
The nonphysician work pool is a separate pool created to
allocate PEs for codes that have only a technical (rather
than professional) component, or codes that are not
performed by physicians. In the Physician Fee Schedule (CY
2000); Payment Policies and Relative Value Unit Adjustment
final rule, published November 2, 1999 (64 FR 59379), we
indicated that “the purpose of this pool was only to protect
the (TC) services from the substantial decreases … until
further refinement could take place…” (64 FR 59406).
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.
On the other hand, 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
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