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CMS-1403-FC
Although not discussed in the CY 2009 PFS proposed
rule, we received comments requesting that CMS apply the
increases in work RVUs for E&M services recommended by the
AMA RUC for each CPT code with a global period of 10 and 90
days as part of the 2007 PFS proposed and final rules to
the inpatient dialysis family of services.
Comment: Some commenters believed that the outpatient
and inpatient dialysis services that use E&M codes as
“building blocks” or components of their valuation should
have the full increases for the E&M codes incorporated into
their values as well.
Response: Increases in E&M codes were not applied to
the inpatient dialysis services because these codes do not
have a global period of 10 or 90 days. The AMA RUC
recommendations were specifically for codes with global
periods of 10 or 90 days. We suggest that the specialty
society work with the AMA RUC using the existing process to
address this issue.
4. New Codes for Re-Examination at the next 5-Year Review
As part of its annual recommendation, the AMA RUC
includes a list identifying new CPT codes which will be
reexamined at the next 5-Year Review of Work RVUs. New CPT
codes that have been added to this list are identified with
925