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

radiologic services that have never <strong>been</strong> part of the MP RVU<br />

review process. The MP RVUs initially assigned to these<br />

codes have not <strong>been</strong> revised because there is a lack of<br />

suitable data on the cost of PLI for technical staff or<br />

imaging centers (where most of these services are<br />

performed).<br />

In the CY 2008 PFS proposed rule (72 FR 38143), we<br />

noted that the PLI workgroup, a subset of the Relative<br />

Value Update Committee (RUC) of the AMA, brought to our<br />

attention the fact that there are approximately<br />

600 services that have TC MP RVUs that are greater than the<br />

PC MP RVUs. The PLI workgroup requested that we make<br />

changes to these MP RVUs and suggested that it is illogical<br />

for the MP RVUs for the TC of a service to be higher than<br />

the MP RVUs for the PC.<br />

We responded that we would like to develop a<br />

resource-based methodology for the technical portion of<br />

these MP RVUs; but that we did not have data to support<br />

such a change. We asked for information about how, and if,<br />

technicians employed by facilities purc<strong>has</strong>e PLI or how<br />

their professional liability is covered. We also asked for<br />

comments on what types of PLI are carried by facilities<br />

that perform these technical services.<br />

86

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