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
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. 56
Due to the ongoing refinement by the RUC of the direct PE inputs, we had expected that the PE RVUs would necessarily fluctuate from year-to-year, frustrating temporarily our efforts to reach the goal of stabilizing the PE portion of the PFS. At the same time, it became apparent that certain aspects of our methodology exacerbated the yearly fluctuations. For example, the need to scale the CPEP costs to equal the SMS costs meant that any changes in the direct PE inputs for one service often leads to unexpected results for other services where the inputs had not been altered. In addition, the services priced by the nonphysician work pool methodology have proved to be especially vulnerable to any change in the pool’s composition. We understand the need for stable PE RVUs, so that physicians and other practitioners can anticipate from year-to-year what the relative payments will be for the services they perform. Now, that the CPEP/RUC refinement of existing services is virtually complete, this appears to be an opportunity for us to propose a way to provide stability to the PE RVUs. Therefore, consistent with our goals of using the most appropriate data, simplifying our methodology, and increasing the stability of the payment system, we are proposing the following changes to our PE methodology: ● Use a Bottom-up Methodology to Calculate Direct PE Costs Instead of using the top-down approach to calculate the direct PE RVUs, where the aggregate CPEP/RUC costs for each 57
- Page 5 and 6: Rick Ensor (410) 786-5617 (for issu
- Page 7 and 8: service of the U.S. Government Prin
- Page 9 and 10: 4. Proposed Revisions to §413.170
- Page 11 and 12: AGA American Gastroenterological As
- Page 13 and 14: GAO General Accounting Office GPCI
- Page 15 and 16: PLI Professional liability insuranc
- Page 17 and 18: Initially, only the physician work
- Page 19 and 20: This resource-based system was base
- Page 21 and 22: effect in 1997, published on Novemb
- Page 23 and 24: ● Revised requirements for superv
- Page 25 and 26: efinement of work RVUs; and solicit
- Page 27 and 28: historical allowed charges. This le
- Page 29 and 30: November 1, 2001 (66 FR 55246).) Th
- Page 31 and 32: The CPEPs identified specific input
- Page 33 and 34: codes that the RUC has not yet revi
- Page 35 and 36: procedure: $27,305,408. In this exa
- Page 37 and 38: as a whole. Indirect costs include
- Page 39 and 40: ● The unscaled indirect expense a
- Page 41 and 42: BNF is applied to (multiplied by) t
- Page 43 and 44: NPWP Step 2--Calculation of Charge-
- Page 45 and 46: In Table 11, the scaled total direc
- Page 47 and 48: TABLE 13--Budget Neutrality and Fin
- Page 49 and 50: The following discussion outlines t
- Page 51 and 52: exist, and suggests that the need f
- Page 53 and 54: TABLE 14--Practice Expense Per Hour
- Page 55: We believe that we have consistentl
- Page 59 and 60: indirect PE methodology is inaccura
- Page 61 and 62: multi-specialty PEAC that were base
- Page 63 and 64: the needed survey or other data or
- Page 65 and 66: PERC/RUC recommendations for these
- Page 67 and 68: eflect the typical number of cast c
- Page 69 and 70: on comments received and additional
- Page 71 and 72: We have reviewed the PE database an
- Page 73 and 74: the ACR. We have accepted the follo
- Page 75 and 76: ● Clinical Labor for G-codes Rela
- Page 77 and 78: proposed associated prices that we
- Page 79 and 80: Supply Code Supply Description Unit
- Page 81 and 82: ● Supply and Equipment Items Need
- Page 83 and 84: Code 2005 Description Unit Unit Pri
- Page 85 and 86: Code 2005 Description Price EQ212 p
- Page 87 and 88: Effective January 1, 2006, this pro
- Page 89 and 90: challenge the validity of a new loc
- Page 91 and 92: ones reconfigured). Yet we also rec
- Page 93 and 94: The issue of payment locality desig
- Page 95 and 96: specialties listed infrequently as
- Page 97 and 98: for premium rating purposes. ISO co
- Page 99 and 100: psychology to the nonsurgical risk
- Page 101 and 102: to anesthesiology which is 2.84 rat
- Page 103 and 104: 103 However, as noted previously in
- Page 105 and 106: ● Category #1: Services that are
Due to the ongoing refinement by the RUC <strong>of</strong> the direct PE<br />
inputs, we had expected that the PE RVUs would necessarily<br />
fluctuate from year-to-year, frustrating temporarily our efforts<br />
to reach the goal <strong>of</strong> stabilizing the PE portion <strong>of</strong> the PFS. At<br />
the same time, it became apparent that certain aspects <strong>of</strong> our<br />
methodology exacerbated the yearly fluctuations. For example,<br />
the need to scale the CPEP costs to equal the SMS costs meant<br />
that any changes in the direct PE inputs for one service <strong>of</strong>ten<br />
leads to unexpected results for other services where the inputs<br />
had not been altered. In addition, the services priced by the<br />
nonphysician work pool methodology have proved to be especially<br />
vulnerable to any change in the pool’s composition. We<br />
understand the need for stable PE RVUs, so that physicians and<br />
other practitioners can anticipate from year-to-year what the<br />
relative payments will be for the services they perform. Now,<br />
that the CPEP/RUC refinement <strong>of</strong> existing services is virtually<br />
complete, this appears to be an opportunity for us to propose a<br />
way to provide stability to the PE RVUs.<br />
Therefore, consistent with our goals <strong>of</strong> using the most<br />
appropriate data, simplifying our methodology, and increasing<br />
the stability <strong>of</strong> the payment system, we are proposing the<br />
following changes to our PE methodology:<br />
● Use a Bottom-up Methodology to Calculate Direct PE Costs<br />
Instead <strong>of</strong> using the top-down approach to calculate the<br />
direct PE RVUs, where the aggregate CPEP/RUC costs for each<br />
57
Change language