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CMS-1403-FC
surgical codes as comparison codes. As noted above, we do
not believe that such codes provide the correct comparison,
which led to an inappropriate valuation of these codes.
Although we disagree with the methodology and valuation of
the add-on codes, we will accept the values as recommended
on an interim basis. We urge the AMA RUC, to the extent
that the type of specialty involved played a part in the
valuation of these codes, to place an emphasis on the type
of work performed, not the specialty provider.
3. Endothelial Keratoplasty
The CPT Editorial Panel created two CPT codes (65756,
Keratoplasty (corneal transplant); endothelial and 65757,
Backbench preparation of corneal endothelial allograft prior
to transplantation (List separately in addition to code for
primary procedure) to describe the physician service of
endothelial keratoplasty, which is a new surgical method of
repairing certain types of diseased corneas that in the past
would have required a full thickness corneal transplant
(also called penetrating keratoplasty). The AMA RUC
recommended 16.60 work RVUs for CPT code 65756 and 1.44 work
RVUs for CPT code 65757. We have accepted the AMA RUC
recommended work RVUs for CPT code 65756; however, we have
decided to have Medicare contractors price CPT code 65757.
We recognize that it is difficult to assess the intensity
and work of the other backbench transplant codes and have
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