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CMS-1403-FC
absence of these changes. If this threshold is exceeded,
we must make adjustments to preserve BN.
The most recent 5-Year Review of the work RVUs was
implemented in 2007 and 2008. We estimated that the 5-Year
Review of work RVUs, including the refinement to the work
RVU changes for the additional codes and the increases in
the work of anesthesia services, would result in a change
in expenditures that would exceed $20 million if we made no
offsetting adjustment. In CY 2007, we met the BN
requirement by applying a separate BN adjustment factor to
the work RVUs of -10.06 percent. In CY 2008, due to
subsequent changes related to the 5-Year Review of work,
the separate BNF for work RVUs was -11.94 percent.
Section 133(b) of the MIPPA requires the Secretary,
instead of continuing to apply the BN adjustment required
as a result of the 5-Year Review of work to the work RVUs,
to apply the required BN adjustment to the CF beginning
with CY 2009. Shifting the 11.94 percent separate work
adjustment to the CF requires a reduction to the CF of 6.41
percent (0.9359). (Work RVUs represent slightly over half
of PFS payments; PE and malpractice RVUs comprise the
rest.) Payments for the work portion of the PFS will
increase as a result of this change. However, this
increase will be offset in the aggregate by the decrease to
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