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CMS-1403-FC
The separate work BN adjustor did not impact payment
for the TC of imaging services, since this portion of the
service does not have work RVUs. When the BN adjustment is
made to the CF as required under section 133(b) of MIPAA,
however, the adjustment does lower payments for the TC of
imaging services. Because the reduction to the CF lowers
the payments for the TC of imaging services, there are less
aggregate savings resulting from the OPPS payment cap under
section 5102 of the DRA with the BN adjustment to the CF
than there are with the separate work BN adjustment. This
is because services will be paid at the OPPS rate both
before and after the application of the BN adjustment,
resulting in no BN savings from these services. We
estimate that the reduction in aggregate savings will be
approximately $0.2 billion in 2009. In other words,
Medicare expenditures in the aggregate will increase by
$0.2 billion relative to what would have occurred in the
absence of section 133(b) of the MIPPA.
As stated earlier, section 1848(c)(2)(B)(ii)(II) of
the Act requires that increases or decreases in RVUs may
not cause the amount of expenditures for the year to differ
by more than $20 million from what expenditures would have
been in the absence of these changes. If this threshold is
exceeded, we must make adjustments to preserve BN. We
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