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 retrieval services exists, and that any rulemaking without such data would be inappropriate. The commenters stated that due to the extreme variability associated with these services, they had serious concerns as to the feasibility of establishing an accurate cost or payment for organ retrieval using an approach like that employed by the AMA’s Relative Value Scale Update Committee (RUC). According to the commenters, there are specific factors impacting the cost of organ retrieval including donor evaluation, travel and wait time, dry runs and other risks and costs. These factors contribute to the great variability in measuring the time and expense associated with organ retrieval services. These commenters offered to assist us in establishing a process to collect data for the purpose of updating the organ retrieval rates. One commenter stated that the retrieval rate should be paid per kidney and not per donor. Response: We thank the commenters who responded to our solicitation of comments and appreciate the offer that some made to be involved in future efforts to design a revised payment method. We are not inclined to propose that the base organ retrieval rate for kidneys and other organs simply be increased by an indexed amount (such as the CPI-U) because we believe the base payment amounts for 774
CMS-1403-FC retrieval of the various organs may need to be updated. Therefore, we are again soliciting information from the transplant community. Specifically we would like to obtain information on the physician effort and resources required to procure an organ. These resources include surgical time, dry runs (number and percentage of retrievals in which an organ is not recovered), travel and wait times, as well as the incremental time required for extended criteria donors and donors after cardiac death. Additionally, because currently we limit kidney retrieval physician reimbursement to $1,250 per donor, we would need resource information to determine the difference in procuring one kidney or a pair of kidneys from a single donor in order to determine a payment on a per kidney basis as suggested by a commenter. 5. Revision to the “Appeals of CMS or CMS contractor Determinations When a Provider or Supplier Fails to Meet the Requirements for Medicare Billing Privileges” Final Rule In the June 27, 2008 Federal Register, we published the “Appeals of CMS or CMS contractor Determinations When a Provider or Supplier Fails to Meet the Requirements for Medicare Billing Privileges” final rule. In §405.874(b)(2), we stated, “The revocation of a provider’s 775
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<strong>CMS</strong>-1403-FC<br />
retrieval services exists, and that any rulemaking without<br />
such data would be inappropriate. The commenters stated<br />
that due to the extreme variability associated with these<br />
services, they had serious concerns as to the feasibility<br />
of establishing an accurate cost or payment for organ<br />
retrieval using an approach like that employed by the AMA’s<br />
Relative Value Scale Update Committee (RUC). According to<br />
the commenters, there are specific factors impacting the<br />
cost of organ retrieval including donor evaluation, travel<br />
and wait time, dry runs and other risks and costs. These<br />
factors contribute to the great variability in measuring<br />
the time and expense associated with organ retrieval<br />
services. These commenters offered to assist us in<br />
establishing a process to collect data for the purpose of<br />
updating the organ retrieval rates. One commenter stated<br />
that the retrieval rate should be paid per kidney and not<br />
per donor.<br />
Response: We thank the commenters who responded to<br />
our solicitation of comments and appreciate the offer that<br />
some made to be involved in future efforts to design a<br />
revised payment method. We are not inclined to propose<br />
that the base organ retrieval rate for kidneys and other<br />
organs simply be increased by an indexed amount (such as<br />
the CPI-U) because we believe the base payment amounts for<br />
774