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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.
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