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<strong>CMS</strong>-1403-FC<br />

● Develop a refinement method to be used during the<br />

transition.<br />

● Consider, in the course of notice and comment<br />

rulemaking, impact projections that compare new proposed<br />

payment amounts to data on actual physician PE.<br />

In CY 1999, we began the 4-year transition to<br />

resource-based PE RVUs utilizing a “top-down” methodology<br />

whereby we allocated aggregate specialty-specific practice<br />

costs to individual procedures. The specialty-specific PEs<br />

were derived from the American Medical Association’s (AMA’s)<br />

Socioeconomic Monitoring Survey (SMS). In addition, under<br />

section 212 of the BBRA, we established a process extending<br />

through March 2005 to supplement the SMS data with data<br />

<strong>submitted</strong> by a specialty. The aggregate PEs for a given<br />

specialty were then allocated to the services furnished by<br />

that specialty on the basis of the direct input data (that<br />

is, the staff time, equipment, and supplies) and work RVUs<br />

assigned to each CPT code.<br />

For CY 2007, we implemented a new methodology for<br />

calculating PE RVUs. Under this new methodology, we use the<br />

same data sources for calculating PE, but instead of using<br />

the “top-down” approach to calculate the direct PE RVUs,<br />

under which the aggregate direct and indirect costs for each<br />

specialty are allocated to each individual service, we now<br />

40

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