2006 proposed fee schedule - American Society of Clinical Oncology

We disagreed with the PERC recommendation for clinical
labor time for CPT code 36522, Extracorporeal Photophoresis.
In last year’s Revisions to Payment Policies Under the
Physician Fee Schedule for Calendar Year 2005 final rule,
published November 15, 2004 (69 FR 66236) we assigned, on an
interim basis, 223 minutes of total clinical labor for the
service period based on the typical treatment time of
approximately 4 hours. The PERC, however, recommended 122
minutes total clinical labor time for the service period,
which allows for 90 minutes of nurse “intra service” time
for the performance of the procedure (the society originally
proposed 180 minutes). We believe that 135 minutes is a
more appropriate estimation of the clinical staff time
actually needed for the intra time, as it more closely
approximates the time assigned to the other procedures in
this family of codes, including CPT codes 36514, 36515, and
36516. Therefore, we are proposing a total clinical labor
time of 167 minutes for the service period.
The PERC/RUC also recommended that no inputs be
assigned to several codes because the services were not
performed in the office setting. However, our utilization
data shows that four of these codes (CPT codes 15852, 76975,
78350, and 86585) are currently priced in the office and are
performed with sufficient frequency in the office to warrant
this. Therefore, we are proposing not to accept the
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