Notice: This CMS-approved document has been submitted - Philips ...
Notice: This CMS-approved document has been submitted - Philips ... Notice: This CMS-approved document has been submitted - Philips ...
CMS-1403-FC clinical rationale for increased utilization, and we will continue to take this into consideration in future reviews. C. AMA RUC Review of Potentially Misvalued Codes The AMA RUC started to review potentially misvalued codes using various screens, including codes with site of service and high IWPUT anomalies and high volume and a new technology designation, at the 2008 AMA RUC meetings. Review of the identified clinical services revealed 204 codes. Of those codes, 48 were recommended for a reduction in valuation; 38 were recommended to maintain the same valuation; 105 were referred to CPT for further code clarification; and 13 were recommended for an increase in valuation. All of these codes were reviewed and revalued by the AMA RUC; other than the codes referred to CPT, we have agreed to accept the valuation for these codes for CY 2009, including the conforming changes to the PE inputs for these codes, as applicable. We recognize that many of the site of service anomaly code changes included deletion or modification of hospital days, office visits, intraservice time, and discharge day management services. We have concerns that the methodology used by the AMA RUC to review the services may have resulted in removal of hospital days and deletion or reallocation of office visits without 884
CMS-1403-FC extraction of the associated RVUs. We also have concerns about the methodology used to value the high IWPUT and new technology codes. We note that the high volume codes have been referred to CPT. Although we have some questions or concerns with certain aspects of the AMA RUC reviews of these codes, we believe the AMA RUC-recommended valuations are still a better representation of the resources used to furnish these services than the current valuations. We will continue to examine the AMA RUC recommendations and will consider whether it would be appropriate to propose further changes in future rulemaking. During the review of the above-noted potentially misvalued codes, the AMA RUC identified three codes that they believed needed review for purposes of the PE inputs only including CPT codes 52214, 52224, and 94770. CPT codes 52214 and 52224 were identified by the high volume growth screen. As a result, the AMA RUC identified a duplication of the PE inputs that included supplies and equipment for both the laser and electrocautery techniques and recommended this duplication be eliminated. After a review of the PE inputs in October 2008, the AMA RUC recommended that the electrocautery PE inputs be deleted. 885
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- Page 853 and 854: CMS-1403-FC Section 414.210(e)(2) a
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- Page 897 and 898: CMS-1403-FC C. Interim 2008 Codes 1
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- Page 901 and 902: CMS-1403-FC CPT codes for 2008. In
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- Page 905 and 906: CMS-1403-FC CPT 1 AMA RUC Work RVU
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- Page 913 and 914: CMS-1403-FC Therefore, we disagree
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<strong>CMS</strong>-1403-FC<br />
clinical rationale for increased utilization, and we will<br />
continue to take this into consideration in future reviews.<br />
C. AMA RUC Review of Potentially Misvalued Codes<br />
The AMA RUC started to review potentially misvalued<br />
codes using various screens, including codes with site of<br />
service and high IWPUT anomalies and high volume and a new<br />
technology designation, at the 2008 AMA RUC meetings.<br />
Review of the identified clinical services revealed<br />
204 codes. Of those codes, 48 were recommended for a<br />
reduction in valuation; 38 were recommended to maintain the<br />
same valuation; 105 were referred to CPT for further code<br />
clarification; and 13 were recommended for an increase in<br />
valuation.<br />
All of these codes were reviewed and revalued by the<br />
AMA RUC; other than the codes referred to CPT, we have<br />
agreed to accept the valuation for these codes for CY 2009,<br />
including the conforming changes to the PE inputs for these<br />
codes, as applicable. We recognize that many of the site<br />
of service anomaly code changes included deletion or<br />
modification of hospital days, office visits, intraservice<br />
time, and discharge day management services. We have<br />
concerns that the methodology used by the AMA RUC to review<br />
the services may have resulted in removal of hospital days<br />
and deletion or reallocation of office visits without<br />
884