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CMS-1403-FC V. Refinement of Relative Value Units for Calendar Year 2009 and Response to Public Comments on Interim Relative Value Units for 2008 A. Summary of Issues Discussed Related to the Adjustment of Relative Value Units Sections IV.B. and IV.C. of this final rule with comment describe the methodology used to review the comments received on the RVUs for physician work and the process used to establish RVUs for new and revised CPT codes. Changes to the RVUs and billing status codes reflected in Addendum B are effective for services furnished beginning January 1, 2009. B. Process for Establishing Work Relative Value Units for the Physician Fee Schedule The CY 2008 PFS final rule with comment period (72 FR 66365) contained the work RVUs for Medicare payment for existing procedure codes under the PFS and interim RVUs for new and revised codes beginning January 1, 2008. We considered the RVUs for the interim codes to be subject to public comment under the annual refinement process. In this section, we address comments on the interim work RVUs published in the CY 2008 PFS final rule with comment period, and our establishment of the work RVUs for new and revised codes for the CY 2009 PFS. 896
CMS-1403-FC C. Interim 2008 Codes 1. Orthopedic Fracture Treatment Codes Orthopedic fracture treatment codes were originally part of the third 5-Year Review of work RVUs. The codes were referred by the AMA RUC to the AMA’s CPT Editorial Panel for further clarification because it was unclear whether the previous valuation for these codes included the circumstance when both internal and external fixation is applied to the fracture site. The CPT Editorial Panel agreed the codes needed further clarification and removed the reference relating to external fixation from the codes. As a result, the AMA RUC examined the various families of fracture codes and recommended increased work RVUs for most of the codes. The codes were submitted to CMS as part of the new and revised codes for CY 2008. Although we agreed with the work RVU recommendations and rank order listing of the codes in each family, the increase in valuation of the services created BN issues within certain fracture code families. In order to retain BN within these families of codes, the work RVUs associated with each code were adjusted. That is, the work RVUs were adjusted so that the sum of the new or revised work RVUs (weighted by projected frequency of use) for each family would be the 897
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<strong>CMS</strong>-1403-FC<br />
C. Interim 2008 Codes<br />
1. Orthopedic Fracture Treatment Codes<br />
Orthopedic fracture treatment codes were originally<br />
part of the third 5-Year Review of work RVUs. The codes<br />
were referred by the AMA RUC to the AMA’s CPT Editorial<br />
Panel for further clarification because it was unclear<br />
whether the previous valuation for these codes included the<br />
circumstance when both internal and external fixation is<br />
applied to the fracture site. The CPT Editorial Panel<br />
agreed the codes needed further clarification and removed<br />
the reference relating to external fixation from the codes.<br />
As a result, the AMA RUC examined the various families<br />
of fracture codes and recommended increased work RVUs for<br />
most of the codes. The codes were <strong>submitted</strong> to <strong>CMS</strong> as part<br />
of the new and revised codes for CY 2008. Although we<br />
agreed with the work RVU recommendations and rank order<br />
listing of the codes in each family, the increase in<br />
valuation of the services created BN issues within certain<br />
fracture code families. In order to retain BN within these<br />
families of codes, the work RVUs associated with each code<br />
were adjusted. That is, the work RVUs were adjusted so<br />
that the sum of the new or revised work RVUs (weighted by<br />
projected frequency of use) for each family would be the<br />
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