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2006 proposed fee schedule - American Society of Clinical Oncology

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current approach. Specialties should no longer experience the<br />

wide fluctuations in payment for a given service due to an<br />

aberrant direct cost scaling factor. Direct PEs should only<br />

change for a service if it is further refined or when prices are<br />

updated, while indirect PEs should change only when there are<br />

changes in the mix <strong>of</strong> specialties performing the service or with<br />

the use <strong>of</strong> any future new survey data for indirect costs.<br />

We recognize that there are still some outstanding issues<br />

that need further consideration, as well as input from the<br />

medical community. For example, although we believe that the<br />

elimination <strong>of</strong> the nonphysician work pool would be, on the<br />

whole, a positive step, some practitioner services, such as<br />

audiology and medical nutrition therapy, would be significantly<br />

impacted by the <strong>proposed</strong> change. In addition, there are still<br />

services, such as the ESRD visit codes, for which we have no<br />

direct input information. Also, as mentioned above, we do not<br />

have current SMS or supplementary survey data to calculate the<br />

indirect costs for most specialties. Further, we do not yet<br />

have accurate utilization for the new drug administration codes<br />

that were created in response to the MMA provision on drug<br />

administration. Therefore, we are not proposing to change the<br />

RVU for these services at this time, but to include them under<br />

our <strong>proposed</strong> methodology in next year’s rule when we have<br />

appropriate data. The <strong>proposed</strong> transition period would give us<br />

the opportunity to work with the affected specialties to collect<br />

62

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