2006 proposed fee schedule - American Society of Clinical Oncology

that, in the aggregate, the refined CPEP data represent, more
reliably, the relative direct costs PE inputs for physician
services.
The major specialties comprising the nonphysician work pool
(radiology, radiation oncology and cardiology) have submitted
supplemental survey data that we are proposing to accept. (See
the discussion on supplementary surveys above.) Now that we have
representative aggregate PE data for these specialties, the
continued necessity and equity of treating these technical
services outside the PE methodology applied to other services is
questionable.
We have also taken steps to make our complex top-down PE
methodology more understandable. For example, we eliminated the
somewhat arcane “linking” of direct cost input data when more
than one CPEP panel reviewed a service and did away with the
confusing and unhelpful distinction between procedure-specific
and indirect equipment. However, we acknowledge that most in
the medical community would find our current methodology, as
described above, neither clear nor intuitive. For example,
because of the need to scale the CPEP/RUC inputs to the SMS PEs
under our top-down methodology, the PE RVUs for a procedure do
not necessarily change proportionately with changes in the
direct inputs. This raises the question as to what would now be
the most straightforward and intuitive methodology for
calculating the direct PE RVUs.
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