Notice: This CMS-approved document has been submitted - Philips ...
Notice: This CMS-approved document has been submitted - Philips ... Notice: This CMS-approved document has been submitted - Philips ...
CMS-1403-FC ● Retrieving prior exams. ● Setting up the IV. ● Preparing and cleaning the room. In addition, we considered that supplies, with the exception of film, are not duplicated for subsequent procedures. To determine the appropriate level of the payment reduction for multiple procedures, we examined multiple pairs of procedure codes from the families representing all modalities (that is, ultrasound, CT/CTA, and MRI/MRA studies) that were frequently performed on a single day based on historical claims data. Using PE input data provided by the RUC, we factored out the clinical staff minutes for the activities we indicated are not duplicated for subsequent procedures, and the supplies, other than film, which we considered are not duplicated for subsequent procedures. We did not assume any reduction in procedure (scanning) time or equipment for subsequent procedures. However, equipment time and indirect costs are allocated based on clinical labor time; therefore, these inputs were reduced accordingly. Removing the PE inputs for activities that are not duplicated, and adjusting the equipment time and indirect costs for the individual pairs of procedures studied, supported payment reductions ranging from 40 to 59 134
CMS-1403-FC percent for the subsequent services. Because we found a relatively narrow range of percentage payment reductions across modalities and families, and taking into consideration that we did not eliminate any duplicative image acquisition time for subsequent procedures in our analysis, we originally proposed an across-the-board MPPR for all 11 families of 50 percent (which is approximately the midpoint of the range established through our analysis). We believe this level of reduction was both justified and conservative (70 FR 45849). To allow for a transition of the changes in payments for these services attributable to this policy, we implemented a 25 percent payment reduction for all code families in CY 2006 which was scheduled to increase to a 50 percent reduction in CY 2007. Subsequent to the publication of the CY 2006 PFS final rule with comment period, section 5102 (b) of the DRA capped the PFS payment for most imaging services at the amount paid under the hospital outpatient prospective payment system (OPPS). In addition, in response to our request for data on the appropriateness of the 50 percent reduction in the CY 2006 PFS final rule with comment period, the American College of Radiology (ACR) provided information for 25 code combinations supporting a reduction 135
- Page 83 and 84: CMS-1403-FC we decided not to proce
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- Page 107 and 108: CMS-1403-FC 99233). For CY 2006, we
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- Page 123 and 124: CMS-1403-FC G0332). The Medicare pa
- Page 125 and 126: CMS-1403-FC code G0332. For CY 2009
- Page 127 and 128: CMS-1403-FC Response: The separate
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- Page 133: CMS-1403-FC CPT Code Short Descript
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- Page 139 and 140: CMS-1403-FC jeopardizes beneficiary
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- Page 159 and 160: CMS-1403-FC add a modifier to their
- Page 161 and 162: CMS-1403-FC application of the AQ m
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- Page 171 and 172: CMS-1403-FC After removing the enro
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- Page 175 and 176: CMS-1403-FC plain language over pol
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<strong>CMS</strong>-1403-FC<br />
● Retrieving prior exams.<br />
● Setting up the IV.<br />
● Preparing and cleaning the room.<br />
In addition, we considered that supplies, with the<br />
exception of film, are not duplicated for subsequent<br />
procedures.<br />
To determine the appropriate level of the payment<br />
reduction for multiple procedures, we examined multiple<br />
pairs of procedure codes from the families representing all<br />
modalities (that is, ultrasound, CT/CTA, and MRI/MRA<br />
studies) that were frequently performed on a single day<br />
based on historical claims data. Using PE input data<br />
provided by the RUC, we factored out the clinical staff<br />
minutes for the activities we indicated are not duplicated<br />
for subsequent procedures, and the supplies, other than<br />
film, which we considered are not duplicated for subsequent<br />
procedures. We did not assume any reduction in procedure<br />
(scanning) time or equipment for subsequent procedures.<br />
However, equipment time and indirect costs are allocated<br />
based on clinical labor time; therefore, these inputs were<br />
reduced accordingly. Removing the PE inputs for activities<br />
that are not duplicated, and adjusting the equipment time<br />
and indirect costs for the individual pairs of procedures<br />
studied, supported payment reductions ranging from 40 to 59<br />
134
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