2006 proposed fee schedule - American Society of Clinical Oncology

challenge the validity of a new locality configuration
established without providing them the opportunity to
comment through the regulatory process (as is our normal
process for making locality changes). In particular,
physicians who are not members of county medical societies
or the CMA did not agree to participate in the proposed
demonstration, and some of them may have challenged its
implementation.
Also, the Medicare PFS currently uses identical GPCIs
to pay for services provided in an area by both physicians
and nonphysician providers such as podiatrists,
optometrists, physical therapists, and nurse practitioners
(NPs). Changing the locality configuration for medical
doctors and doctors of osteopathic medicine, but not for
other professionals, would have some peculiar results that
were not addressed in the CMA proposal. For example, in
areas where the GPCIs would be reduced under the
demonstration, some practitioners not participating under
the demonstration (such as physical therapists) could be
paid more than physicians in the same locality. Conversely,
where the GPCIs would be increased under the demonstration,
there would likely be complaints from the nonphysician
practitioners (NPP) not included in the demonstration.
Nonetheless, we do recognize the potential impact of
wide variations in the practice costs within a single
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