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CMS-1403-FC
limitations of the data we received and determine how to
revise our proposed process to elicit better data. We will
propose a revised process in future rulemaking.
2. Review of Services Often Billed Together and the
Possibility of Expanding the Multiple Procedure Payment
Reduction (MPPR) to Additional Non-Surgical Procedures
In the CY 2009 PFS proposed rule, we stated that we
plan to perform data analysis on non-surgical CPT codes
that are often billed together (for example, 60 to 70
percent of the time). This would determine if there are
inequities in PFS payments that are a result of variations
between services or in the comprehensiveness of the codes
used to report the services or in the payment policies
applied to each (for example, global surgery and MPPRs).
The rationale for the MPPR is that clinical labor
activities, supplies and equipment may not be performed or
furnished twice when multiple procedures are performed. We
stated that we would consider developing a proposal either
to bundle additional services or expand application of the
MPPR to additional procedures.
Comment: MedPAC requested that we consider
duplicative physician work, as well as PE, in any expansion
of the MPPR. Several specialty groups noted that the AMA
RUC has already taken action to identify frequently
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