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CMS-1403-FC
identified as having higher TC MP RVUs than PC MP RVUs.
The commenters stated that any premium data received would
represent general liability insurance, not liability
insurance premium data related to nonphysician clinical
personnel. The commenters suggested that premium data does
not exist to support a resource-based computation of the MP
RVUs for the TC and stated that general liability insurance
premiums are included in the PE component and should not be
part of the MP RVU calculation.
Response: We appreciate the comments in support of
our proposal to instruct our contractor to research
available data sources for the MP costs associated with the
TC portions of these codes. As we stated in the CY 2008
PFS final rule with comment period (72 FR 66248), we are
not able to evaluate whether sufficient data exists or to
make a judgment on the RUC’s assertion that such data are
not available. It is possible that the contractor
responsible for collecting the data for the 5-year MP RVU
update will identify providers of professional liability
insurance for nonphysician clinical personnel. We plan to
share the information received on a potential source of
such data with our contractor. If such premium data can be
identified, it will be incorporated into the MP RVU update.
In the event that we adopt such data, we will ensure there
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