CMS Proposes 2012 Payment Changes for 290 Codes

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  • July 1, 2011
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The Centers for Medicare & Medicaid Services (CMS) has proposed revisions to the work relative value units (RVUs) for 290 CPT® codes to be enacted with adoption of the 2012 Medicare Physician Fee Schedule (Jan. 1, 2012).

By law, CMS must review RVUs no less often than every five years. CMS’ recommendations following the most recent five-year review are detailed in a proposed rule posted to the Federal Register on June 6.

Included in the five-year review were services submitted through public comment and by Medicare contractor medical directors, as well as a number of potentially misvalued codes identified by CMS (for example, codes with site-of-service anomalies). Of the 290 codes CMS identified for review, the American Medical Association’s (AMA’s) Relative Value System Update Committee (RUC) provided differing recommendations for 173 codes. Upon clinical review, CMS is proposing to accept 89 of the AMA RUC recommendations for work RVUs.

The proposed RVU changes are summarized in Table 5 of the proposed rule. As an example, CMS is proposing .44 work RVUs for CPT® 11732 Avulsion of nail plate, partial or complete, simple; each additional nail plate (list separately in addition to code for primary procedure), down from .57 RVUs in the 2011 Physician Fee Schedule. In contrast, CMS proposes increasing work RVUs for 12035 Repair, intermediate, wounds of scalp, axillae, trunk and/or extremities (excluding hands and feet); 12.6 cm to 20.0 cm from 3.47 to 3.50 RVUs.

In some cases, CMS refined physician times for codes as deemed appropriate to correspond with the proposed work RVUs. These changes are summarized in Table 6 of the proposed rule. As an example, CMS has proposed decreasing the intraservice time allotted for 11732 from 20 minutes to 10 minutes (which also explains why this code would be targeted for an RVU decrease).

According to CMS, the proposed revisions “reflect changes in medical practice and coding that affect the relative amount of physician work required to perform each service …” As an additional consideration, RVU changes must be “budget neutral” under the law.  Increases or decreases in RVUs “may not cause the amount of expenditures under Part B for the year to differ more than $20 million from what it would have been in the absence of these changes.”

The proposed rule provides a full explanation of proposed changes for each code. CMS will collect public comments on the proposed rule until July 25, with a final rule to follow.

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