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CMS-1403-FC We noted in the CY 2009 PFS proposed rule (73 FR 38513), that the physician work GPCIs we calculated did not reflect the 1.000 floor that was in place during CY 2006 through June 30, 2008. However, as discussed in section III. of this preamble, section 134 of the MIPPA of 2008 extended the 1.000 work GPCI floor from July 1, 2008, through December 31, 2009. Additionally, section 134(b) of the MIPPA sets a permanent 1.500 work GPCI floor in Alaska for services furnished beginning January 1, 2009. As such, the CY 2009 GPCIs and summarized GAFs reflect these statutorily mandated work GPCI floors. See Addenda D and E for the CY 2009 GPCIs and summarized geographic adjustment factors (GAFs). For a detailed explanation of how the GPCI update was developed, see the CY 2008 PFS final rule with comment period (72 FR 66244). 2. Payment Localities a. Background As stated above in this section, section 1848(e)(1)(A) of the Act requires us to develop separate GPCIs to measure resource cost differences among localities compared to the national average for each of the three fee schedule components (work, PE, and malpractice). Payments under the PFS are based on the relative resources required to provide 78

CMS-1403-FC services, and are adjusted for differences in resource costs among payment localities using the GPCIs. As a result, PFS payments vary between localities. Although the PFS payment for a particular service is actually adjusted by applying a GPCI to each fee schedule component, for purposes of discussion and comparison, we calculate a geographic adjustment factor (GAF) for each locality. These GAFs reflect a weighted average of the GPCIs within the locality and can be used as a general proxy for area practice costs. A GAF is calculated to reflect a summarization of the GPCIs, (which is used only to make comparisons across localities). The GAFs are not an absolute measure of actual costs, nor are they used to calculate PFS payments. Rather, they are a tool that can be used as a proxy for differences in the cost of operating a medical practice among various geographic areas (for example counties) for the purpose of assessing the potential impact of alternative locality configurations. Prior to 1992, Medicare payments for physicians’ services were made on the basis of reasonable charges. Payment localities were established under the reasonable charge system by local Medicare carriers based on their knowledge of local physician charging patterns and economic conditions. A total of 210 localities were developed; 79

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

We noted in the CY 2009 PFS proposed rule (73 FR 38513),<br />

that the physician work GPCIs we calculated did not reflect<br />

the 1.000 floor that was in place during CY 2006 through<br />

June 30, 2008. However, as discussed in section III. of<br />

this preamble, section 134 of the MIPPA of 2008 extended<br />

the 1.000 work GPCI floor from July 1, 2008, through<br />

December 31, 2009. Additionally, section 134(b) of the<br />

MIPPA sets a permanent 1.500 work GPCI floor in Alaska for<br />

services furnished beginning January 1, 2009. As such, the<br />

CY 2009 GPCIs and summarized GAFs reflect these statutorily<br />

mandated work GPCI floors.<br />

See Addenda D and E for the CY 2009 GPCIs and<br />

summarized geographic adjustment factors (GAFs).<br />

For a detailed explanation of how the GPCI update was<br />

developed, see the CY 2008 PFS final rule with comment<br />

period (72 FR 66244).<br />

2. Payment Localities<br />

a. Background<br />

As stated above in this section, section 1848(e)(1)(A)<br />

of the Act requires us to develop separate GPCIs to measure<br />

resource cost differences among localities compared to the<br />

national average for each of the three fee schedule<br />

components (work, PE, and malpractice). Payments under the<br />

PFS are based on the relative resources required to provide<br />

78

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