Final MPFS 2014 Summary SIR

Transcription

1 Final MPFS 2014 Summary SIR The CY 2014 PFS CF is $ (p531) Impact Tables (p1285) Refinement Panel Recommendations (p183) Table 23 presents information on the work RVUs for the codes considered by the refinement panel, including the refinement panel ratings and the final CY 2014 work RVUs. CY 2013 interim final work RVUs (p184) Table 24 of this final rule with comment period lists all codes that had a CY 2013 interim final work value. This chart provides the CY 2013 work RVUs, the CY 2014 work RVUs and indicates whether they are finalizing the CY 2014 work RVUs. Page 1

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5 Cardiovascular System: Arteries and Veins (CPT codes 35475, 35476, ) (p228) CMS referred CPT codes and to the CY 2013 multi-specialty refinement panel for further consideration because the requirements for refinement panel review were met. The refinement panel median work RVU for CPT codes and were 6.60 and 5.10, respectively. After reevaluation, they are finalizing work RVUs of 6.60 for CPT code and 5.10 for CPT code 35476, based upon the refinement panel median. After re-review of CPT codes , they maintain that the recommended direct crosswalks for these services are appropriate because the codes involve similar work and, as such, should be valued relative to one another. They also disagree with the commenters that efficiencies do not occur when surgical codes and S&I codes are bundled. Therefore, they are finalizing the CY 2013 interim final values for CY 2014 for CPT codes They are also finalizing the postservice time refinement of 30 minutes to CPT codes for CY Cardiovascular System: Arteries and Veins (CPT codes and 37214) (p232) Based upon the comments received, they re-reviewed CPT codes and Based upon their review, they believe that directly crosswalking CPT code to CPT code and reducing CPT code by a conservative 10 percent to account for efficiencies gained when services are bundled are appropriate to establish values for these services and produce RVUs that fully reflect the typical work and intensity of the procedures. Therefore, they are finalizing the work RVU of 6.29 for CPT code and 2.74 for CPT code for CY Noninvasive Vascular Diagnostic Studies: Extremity Arterial Studies (Including Digits) (CPT codes and 93926) (p250) After evaluation of the request for refinement, they determined that the criteria for the request for refinement were not met and, as a result, they did not refer CPT codes and to the CY 2013 multi-specialty refinement panel for further review. Page 5

6 Establishing CY 2014 Interim Final RVUs (p312) Page 6

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8 Transcatheter Placement Intravascular Stent (CPT Code 37236, 37237, 37238, and 37239)(p341) For CY 2014, the CPT Editorial Panel deleted four intravascular stent placement codes and created four new bundled codes, CPT codes 37236, 37237, 37238, and CMS agreed with the AMA RUC recommendations for all of the codes in the family except CPT code The AMA RUC recommended a work RVU of 3.34 for CPT code 37239, which they crosswalked to the work value of (Creation of distal arteriovenous fistula during lower extremity bypass surgery (non-hemodialysis) (List separately in addition to code for primary procedure)). CPT code is the add-on code to for placement of an intravascular stent in each additional vein. The AMA RUC valued placement of a stent in the initial artery (CPT code 37236) at 9.0 work RVUs and its corresponding add-on code (37237) for placement of a stent in an additional artery at 4.25 work RVUs. After review, they believe that the ratio of the work of placement of the initial stent and additional stents would be the same regardless of whether the stent is placed in an artery or a vein, and that the appropriate ratio is found in the AMA RUC-recommended work RVUs of CPT codes and To determine the work RVU for CPT code 37239, they applied that ratio to the AMA RUC-recommended work RVU of 6.29 for CPT code Therefore, they are assigning an interim final work RVU of 2.97 to CPT code for CY Embolization and Occlusion Procedures (CPT Codes 37241, 37242, 37243, and 37244) (p340) For CY 2014, the CPT Editorial Panel deleted CPT code (transcatheter occlusion or embolization (eg, for tumor destruction, to achieve hemostasis, to occlude a vascular malformation), percutaneous, any method, non-central nervous system, non-head or neck)) and created four new bundled codes to describe embolization and occlusion procedures, CPT codes 37241, 37242, 37423, and CMS agreed with the AMA RUC recommendations for CPT codes and However, they disagree with the AMA RUC-recommended work RVU of for CPT code The AMA RUC recommended a direct crosswalk to CPT code (Open iliac artery exposure with creation of conduit for delivery of aortic or iliac endovascular prosthesis, by abdominal or retroperitoneal incision, unilateral) because of the similarity in intraservice time. The service described by CPT code was previously reported using CPT codes (Transcatheter occlusion or embolization (eg, for tumor destruction, to achieve hemostasis, to occlude a vascular malformation), percutaneous, any method, noncentral nervous system, non-head or neck, (Transcatheter therapy, embolization, any method, radiological supervision and interpretation), and (Angiography through existing catheter for follow-up study for transcatheter therapy, embolization or infusion, other than for thrombolysis). The intraservice time for CPT code is 240 minutes and the work RVU is The AMA RUC recommended intraservice time for CPT code is 100 minutes. They believe that the AMA RUC recommended work RVU does not adequately consider the substantial decrease in intraservice time for CPT code as compared to CPT code Therefore, they believe that the survey s 25th percentile work RVU of is consistent with the decreases in intraservice time and more appropriately reflects the work of this procedure. Page 8

9 They also disagree with the AMA RUC-recommended work RVU of for CPT code 37243, which the AMA RUC crosswalked from CPT code 37244, which has a work RVU of The AMA RUC stated that work RVU of CPT codes and should be the same despite a 30-minute intraservice time difference between the codes because the work of CPT code (recommended intraservice time of 90 minutes) was more intense than CPT code (recommended intraservice time of 120 minutes). This service was previously reported using CPT codes 37204, and 75898; or (Uterine fibroid embolization (UFE, embolization of the uterine arteries to treat uterine fibroids, leiomyoma), percutaneous approach inclusive of vascular access, vessel selection, embolization, and all radiological supervision and interpretation, intraprocedural roadmapping, and imaging guidance necessary to complete the procedure). The current intraservice time for CPT code is 240 minutes and the work RVU is The current intraservice time for CPT code is 90 minutes and the work RVU is The AMA RUC-recommended intraservice time for is 120 minutes. They do not believe that the AMA RUC-recommended work RVU adequately considers the substantial decrease in intraservice time for CPT code as compared to CPT code CMS believes that the survey s 25th percentile work RVU of more appropriately reflects the work required to perform this service. Duplex Scans (CPT Codes 93880, 93882, 93925, 93926, 93930, 93931, 93970, 93971, 93975, 93976, and 93979) (p363) CPT Code was identified as a high expenditure procedure code and referred to the AMA RUC for review. As part of its recommendations, the AMA RUC included recommendations for CPT code The AMA RUC recommended an increase in the work RVUs for and from 0.60 and 0.40 to 0.80 and 0.50, respectively. In the 2013 PFS final rule with comment period, CMS reviewed (Duplex scan of lower extremity arteries or arterial bypass grafts; complete bilateral study) and (Duplex scan of lower extremity arteries or arterial bypass grafts; unilateral or limited study), which were identified by the AMA RUC as potentially misvalued because the time and PE inputs for these services were Harvard valued and these services have utilization of 500,000 service per year. CMS disagreed with the respective AMA RUC recommended work RVUs of 0.90 and 0.70 and established interim final values of 0.80 and 0.50 instead. They believe the AMA RUC-recommended values for these two sets of codes do not maintain the appropriate relative values within the family of duplex scans. In addition to these four codes, there are several other duplex scan codes that may fit within this family, including CPT codes: (Duplex scan of extracranial arteries; complete bilateral study), (Duplex scan of extracranial arteries; unilateral or limited study), (Duplex scan of lower extremity arteries or arterial bypass grafts; complete bilateral study), (Duplex scan of lower extremity arteries or arterial bypass grafts; unilateral or limited study), (Duplex scan of upper extremity arteries or arterial bypass grafts; complete bilateral study), (Duplex scan of upper extremity arteries or arterial bypass grafts; unilateral or limited study), (Duplex scan of extremity veins including responses to compression and other maneuvers; complete bilateral study), (Duplex scan of extremity veins including responses to compression and other maneuvers; unilateral or limited study), (Duplex scan of arterial inflow and venous outflow of abdominal, pelvic, scrotal contents and/or retroperitoneal organs; complete study), Page 9

10 93976 (Duplex scan of arterial inflow and venous outflow of abdominal, pelvic, scrotal contents and/or retroperitoneal organs; limited study), (Duplex scan of aorta, inferior vena cava, iliac vasculature, or bypass grafts; complete study) and (Duplex scan of aorta, inferior vena cava, iliac vasculature, or bypass grafts; unilateral or limited study). They are concerned that the AMA RUC-recommended values for and 93882, as well as the interim final values for and 93926, do not maintain the appropriate relativity within this family and they are referring the entire family to the AMA RUC to assess relativity among the codes and then recommend appropriate work RVUs. They also request that the AMA RUC consider CPT codes (Transcranial Doppler study of the intracranial arteries; complete study) and (Transcranial Doppler study of the intracranial arteries; limited study) in conjunction with the duplex scan codes in order to assess the relativity between and among these codes. Therefore, they will maintain the CY 2013 RVUs for CPT codes and on an interim final basis until they receive further recommendations from the AMA RUC. Selective Catheter Placement (CPT codes and 75726) (p373) The AMA RUC submitted new direct PE inputs for CPT code (Selective catheter placement, arterial system; each first order abdominal, pelvic, or lower extremity artery branch, within a vascular family). They have reviewed the recommended direct PE inputs for this service and made the applicable standard and common refinements which are reflected in the final CY 2014 PFS direct PE input database and detailed in Table 29. However, they note that the review of CPT code was initiated based on the identification of the code through two misvalued code screens. One of these was the screen that identifies codes reported together at least 75 percent of the time. As the RUC noted in its recommendation, CPT may be reported with a number of different radiologic supervision and interpretation codes including (Angiography, visceral, selective or supraselective (with or without flush aortogram), radiological supervision and interpretation). The AMA RUC recommendation stated that, because these code combinations were valued as individual component codes, no potential for duplication of physician work exists. The recommended direct PE inputs for CPT did not address whether or not the direct PE inputs for CPT code should be updated given that it is typically reported with CPT code The current direct PE inputs for include 73 clinical labor minutes for assist physician in performing procedure. This time matches the precise number of minutes assumed for the same task for CPT code in the existing direct PE inputs. The AMA RUC has recommended changing the amount of time considered typical for that task from 73 minutes to 45 minutes and they are accepting that change, without refinement, on an interim final basis for CY Given that these codes are typically reported together and the underlying procedure time assumption used in valuing is dependent on the assumed times for 36245, they believe it is appropriate to make a corresponding change to on an interim final basis to reflect the best estimate of resources for these services which are frequently furnished together. This change is reflected in the final CY 2014 PFS direct PE input database and detailed in Table 29. Page 10

11 Using OPPS and ASC Rates in Developing PE RVUs (p68) CMS does not believe that the direct practice expense information they currently use to value these codes is accurate or reflects typical resource costs. CMS is not finalizing their proposed policy in this final rule with comment period. They will consider more fully all the comments received, including those suggesting technical improvements to their proposed methodology. After further consideration of the comments, they expect to develop a revised proposal for using OPPS and ASC rates in developing PE RVUs, which they will propose through future notice and comment rulemaking. Ultrasound Equipment Recommendations (p78) CMS will continue to consider the perspectives offered by these commenters in developing future proposals regarding the pricing of individual items and equipment packages. Ultrasound Equipment Input Recommendations for Particular Services (p87) CMS believes that the issue of equipment room packages should be addressed in future rulemaking. Based on these comments, they are finalizing the use of the existing room, ultrasound, vascular (EL016) as a proxy for resource costs for these services pending future consideration of equipment room packages. CPT Code (p91) CMS is finalizing their adjustment to the clinical labor minutes associated with this code, as proposed. Potentially Misvalued Codes (p104) CMS will proceed as they proposed in the CY 2014 proposed rule to consider the codes identified by CMDs as potentially misvalued codes Ultrasound Guidance Codes Proposed as Potentially Misvalued (p109) CMS agreed that code is not a code used to supplement a surgical procedure and therefore does not raise the concerns they discussed in the proposed rule. Accordingly, it will not be included on the list of potentially misvalued codes. Multiple Procedure Payment Reduction Policy (p115) CMS did not propose and are not adopting any new MPPR policies for CY However, they continue to look at expanding the MPPR based on efficiencies when multiple procedures are furnished together. Page 11