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

occurring code pairs. The commenters support the AMA RUC’s<br />

recommendation that <strong>CMS</strong> analyze data to identify<br />

nonsurgical CPT codes that are billed together 90 to 95<br />

percent of the time. Other commenters did not believe a<br />

broad-based application of the MPPR to non-surgical<br />

services was appropriate.<br />

Response: Based on the comments received, we will<br />

continue to work with the AMA RUC, MedPAC, and the<br />

specialty societies to determine whether there are<br />

additional services that should be either bundled or<br />

subjected to a MPPR.<br />

B. Requested Approaches for the RUC to Utilize<br />

In the CY 2009 PFS proposed rule, we identified<br />

methods that the AMA RUC could undertake to assist in<br />

identifying potentially misvalued services including<br />

reviewing: (1) the Fastest Growing Procedure Codes; (2)<br />

the Harvard-Valued Codes; and (3) PE RVUs (see<br />

73 FR 38586).<br />

Comment: We received many comments on this issue from<br />

various specialty groups and medical societies. Some<br />

commenters supported our proposed approaches and looked<br />

forward to participating in the process, while others<br />

expressed concern. Some specialty societies are opposed to<br />

our selection of the fastest growing procedure codes based<br />

881

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