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CMS-1403-FC
IV. Potentially Misvalued Services Under the Physician Fee
Schedule
A. Valuing Services under the Physician Fee Schedule
As explained in the CY 2009 PFS proposed rule
(73 FR 38582), the AMA RUC provides recommendations to CMS
for the valuation of new and revised codes, as well as
codes identified as misvalued under the 5-Year Review of
Work. On an ongoing basis, the RUC’s PE Subcommittee
reviews direct PE (clinical staff, medical supplies,
medical equipment) for individual services and examines the
many broad and methodological issues relating to the
development of PE RVUs.
There has been considerable concern expressed by the
Medicare Payment Advisory Commission (MedPAC), the
Congress, and other stakeholders in accurate pricing under
the PFS. Despite the large increase in work RVUs for many
medical visits during the last 5-Year Review of physician
work, there continues to be concern that the presence of
many overvalued procedures within the PFS disadvantages
primary care services and creates distortions in the PFS.
Critics have stated the relative imbalance in the number of
codes for which the work RVUs are increased rather than
decreased in the three 5-Year Reviews of work RVUs.
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