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CMS-1403-FC RUC, the AMA, two State medical societies, a vaccine manufacturer, a pharmaceutical research association, and the National Vaccine Advisory Committee regarding our omission of the QA clinical labor time for the immunization injection codes. These commenters requested that we add back the QA clinical time as recommended by the AMA RUC. Response: Based on the commenters’ requests, we reexamined the issue. We have identified clinical QA time included in other services that is not based on a statutory requirement. For, many cardiac and vascular ultrasound services, for example, QA time is included because it is directly related to compliance with accreditation requirements. After our review, we believe there was evidence to support the inclusion of this QA time in this case in order to comply with State and Federal regulatory guidelines. We have revised the PE database to reflect QA time for these immunization services. Comment: Other commenters representing specialty societies supported our acceptance of the AMA RUC recommendations for the 15 other services identified in Table 2 of the proposed rule. Response: We have finalized the AMA RUC PE recommendations for these services. b. Equipment time-in-use 62
CMS-1403-FC The formula for estimating the cost per minute for equipment is based upon a variety of factors, including the cost of the equipment, useful life, interest rate, maintenance cost, and utilization. The purpose of this formula is to identify an estimated cost per minute for the equipment that can be multiplied by the time the equipment is in use to obtain an estimated per use equipment cost to develop the resource-based PE RVU. In calculating the estimated cost per minute for services that are in use 24 hours per day for 7 days per week, we have assumed that the maximum amount of time that the equipment can be in use is approximately 525,000 minutes (that is, 525,000 minutes = (24 hours per day) x (7 days per week) x (52 weeks per year) x (60 minutes per hour)). For CY 2008, we used 525,000 minutes to calculate the per minute equipment cost for the equipment used in CPT code 93012, Telephonic transmission of post-symptom electrocardiogram rhythm strip(s), 24-hour attended monitoring, per 30 day period of time; tracing only and CPT code 93271, Patient demand single or multiple event recording with presymptom memory loop, 24-hour attended monitoring, per 30 day period of time; monitoring, receipt of transmissions, and analysis. Based on information 63
- Page 11 and 12: CMS-1403-FC 11 Schedule C. Malpract
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- Page 17 and 18: CMS-1403-FC 17 XIII. Waiver of Prop
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- Page 21 and 22: CMS-1403-FC 21 E/M Evaluation and m
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- Page 25 and 26: CMS-1403-FC 25 OSCAR Online Survey
- Page 27 and 28: CMS-1403-FC 27 WAMP Widely availabl
- Page 29 and 30: CMS-1403-FC 29 2. Practice Expense
- Page 31 and 32: CMS-1403-FC 31 extent practicable a
- Page 33 and 34: CMS-1403-FC 33 AMA's Current Proced
- Page 35 and 36: CMS-1403-FC 35 Payment = [(RVU work
- Page 37 and 38: CMS-1403-FC 37 legislation, the PFS
- Page 39 and 40: CMS-1403-FC that time, PE RVUs were
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- Page 43 and 44: CMS-1403-FC ● All other expenses,
- Page 45 and 46: CMS-1403-FC b. Allocation of PE to
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- Page 55 and 56: CMS-1403-FC indirect PE for all PFS
- Page 57 and 58: CMS-1403-FC • Physical therapy ut
- Page 59 and 60: CMS-1403-FC TABLE 1: Calculation of
- Page 61: CMS-1403-FC 2. PE Proposals for CY
- Page 65 and 66: CMS-1403-FC arbitrary method for ch
- Page 67 and 68: CMS-1403-FC We received no comments
- Page 69 and 70: CMS-1403-FC (iv) Contractor Pricing
- Page 71 and 72: CMS-1403-FC Response: We will ask t
- Page 73 and 74: Code CMS-1403-FC 2008/9 Description
- Page 75 and 76: CMS-1403-FC TABLE 4: Practice Expen
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- Page 79 and 80: CMS-1403-FC services, and are adjus
- Page 81 and 82: CMS-1403-FC by at least 5 percent,
- Page 83 and 84: CMS-1403-FC we decided not to proce
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- Page 87 and 88: CMS-1403-FC In the CY 2008 PFS fina
- Page 89 and 90: CMS-1403-FC are available, we would
- Page 91 and 92: CMS-1403-FC is no duplication of co
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- Page 95 and 96: CMS-1403-FC PFS final rule with com
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- Page 107 and 108: CMS-1403-FC 99233). For CY 2006, we
- Page 109 and 110: CMS-1403-FC follow-up inpatient con
- Page 111 and 112: CMS-1403-FC As noted previously, CP
<strong>CMS</strong>-1403-FC<br />
RUC, the AMA, two State medical societies, a vaccine<br />
manufacturer, a pharmaceutical research association, and<br />
the National Vaccine Advisory Committee regarding our<br />
omission of the QA clinical labor time for the immunization<br />
injection codes. These commenters requested that we add<br />
back the QA clinical time as recommended by the AMA RUC.<br />
Response: Based on the commenters’ requests, we<br />
reexamined the issue. We have identified clinical QA time<br />
included in other services that is not based on a statutory<br />
requirement. For, many cardiac and vascular ultrasound<br />
services, for example, QA time is included because it is<br />
directly related to compliance with accreditation<br />
requirements. After our review, we believe there was<br />
evidence to support the inclusion of this QA time in this<br />
case in order to comply with State and Federal regulatory<br />
guidelines. We have revised the PE database to reflect QA<br />
time for these immunization services.<br />
Comment: Other commenters representing specialty<br />
societies supported our acceptance of the AMA RUC<br />
recommendations for the 15 other services identified in<br />
Table 2 of the proposed rule.<br />
Response: We have finalized the AMA RUC PE<br />
recommendations for these services.<br />
b. Equipment time-in-use<br />
62
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