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CMS-1403-FC leads. CPT codes 93282 through 93284 (0.85 to 1.25 work RVUs, with a work RVU difference between the codes of 0.07 to 0.33) describe the programming of ICDs according to the number of leads. We note that the recommended difference in the work RVUs between CPT code 93279 (single lead programming pacemaker code) and CPT code 93282 (single lead ICD code) is 0.20 work RVUs, and that the difference between CPT code 93281 (multiple lead programming pacemaker code) and CPT code 93284 (multiple lead ICD code) is 0.35 work RVUs. The AMA RUC primarily used a comparison methodology to determine the value of the pacemaker codes and the surveyed 25 th percentile to determine the value of the implantable cardioverter defibrillator (ICD) codes. Even though different methodologies were utilized to develop the recommended values, we do not understand why the increments between various levels of the pacemaker programming codes are not also the appropriate increment between the various levels of ICD programming codes. Therefore, we are not accepting these recommendations and instead will establish work RVUs that maintain the same incremental difference between levels of programming codes. This change will help to ensure consistency and relativity within all cardiac device monitoring codes. The specific changes to the codes are discussed below. 916

CMS-1403-FC In addition, we believe that although the surveyed 25 th percentile of 1.18 work RVUs was chosen for valuation of CPT code 93283, the increment of 0.33 work RVUs between CPT codes 93282 and 93283 is excessive. Therefore, we believe that the appropriate value for CPT code 93283 is 1.05 work RVUs, slightly below the 25th percentile. We believe that an appropriate comparison CPT code for 93283 is CPT code 93890 (Transcranial Doppler study of the intracranial arteries; vasoreactivity study) which has a work RVU of 1.00. CPT code 93286 (0.30 work RVUs) describes periprocedural programming of a pacemaker. CPT code 93287 (0.45 work RVUs) describes periprocedural programming of an ICD. These codes have recommended work RVU differences of 0.15 work RVUs and 0.30 work RVUs between the pacemakers and ICDs for a single service and for services pre- and postsurgery, respectively. CPT code 93288 (0.43 work RVUs) describes in person interrogation of pacemakers. CPT Code 93289 (0.92 work RVUs, which was developed by means of a crosswalk to a 99213 office visit) describes in person interrogation of an ICD, a work RVU difference of 0.49 RVUs between the pacemakers and ICDs. As noted above, the work RVU difference between programming pacemakers and ICDs varies from 0.20 to 0.35. Therefore, we believe that the appropriate value for CPT 917

<strong>CMS</strong>-1403-FC<br />

In addition, we believe that although the surveyed<br />

25 th percentile of 1.18 work RVUs was chosen for valuation<br />

of CPT code 93283, the increment of 0.33 work RVUs between<br />

CPT codes 93282 and 93283 is excessive. Therefore, we<br />

believe that the appropriate value for CPT code 93283 is<br />

1.05 work RVUs, slightly below the 25th percentile. We<br />

believe that an appropriate comparison CPT code for 93283<br />

is CPT code 93890 (Transcranial Doppler study of the<br />

intracranial arteries; vasoreactivity study) which <strong>has</strong> a<br />

work RVU of 1.00. CPT code 93286 (0.30 work RVUs)<br />

describes periprocedural programming of a pacemaker. CPT<br />

code 93287 (0.45 work RVUs) describes periprocedural<br />

programming of an ICD. These codes have recommended work<br />

RVU differences of 0.15 work RVUs and 0.30 work RVUs<br />

between the pacemakers and ICDs for a single service and<br />

for services pre- and postsurgery, respectively. CPT code<br />

93288 (0.43 work RVUs) describes in person interrogation of<br />

pacemakers. CPT Code 93289 (0.92 work RVUs, which was<br />

developed by means of a crosswalk to a 99213 office visit)<br />

describes in person interrogation of an ICD, a work RVU<br />

difference of 0.49 RVUs between the pacemakers and ICDs.<br />

As noted above, the work RVU difference between<br />

programming pacemakers and ICDs varies from 0.20 to 0.35.<br />

Therefore, we believe that the appropriate value for CPT<br />

917

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