Creation/Revision Date: January 03, 2012
December 29, 2011
Marilyn B. Tavenner, Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
P.O. Box 8013
Baltimore, MD 21244-8013
Subject: CMS-1524-FC Medicare Program; Revisions to Payment Policies Under the Physician Payment Schedule and Other Revisions to Part B for CY 2012; Final Rule
Dear Acting Administrator Tavenner:
The Renal Physicians Association (RPA) is the professional organization of nephrologists whose goals are to ensure optimal care under the highest standards of medical practice for patients with renal disease and related disorders. RPA acts as the national representative for physicians engaged in the study and management of patients with renal disease. We are writing to provide comments on selected portions of the 2012 Medicare Fee Schedule Final Rule.
RPA’s comments will focus on the following issues:
||Relationship Between Inpatient Dialysis Services and Component Evaluation and Management Services
||CMS Refinement of Relative Value Units for Hemodialysis Vessel Mapping Services
Relationship Between Inpatient Dialysis Services and Component Evaluation and Management Services
RPA continues to believe that the relationship between the family of inpatient dialysis services and the evaluation and management (E&M) service (CPT code 99232, level two hospital visit) that serves as its primary practice expense component code will be out of alignment when the revised practice expense methodology is fully implemented in 2013. Recall that in the Medicare Physician Fee Schedule Final Rule for CY 1995 published on December 8, 1994, and in Transmittal 1776, Change Request 2321 of the Medicare Claims Manual, HCFA/CMS states in both documents that:
“We will bundle payment for subsequent hospital visits (CPT code 99231 through 99233) and follow-up inpatient consultations (CPT codes 99261 through 99263) into the fee schedule amounts for inpatient dialysis (CPT codes 90935 through 90947).”
While follow-up inpatient consultations (CPT codes 99261 through 99263) have been deleted from the fee schedule for payment purposes, the subsequent hospital visit codes are of course still part of the fee schedule. However, as of 2013, when the revised practice expense values for the fee schedule are fully implemented, the PE RVUs for CPT code 90935 (inpatient hemodialysis, single evaluation, which serves as the anchor for the inpatient dialysis code family) will be 0.53, while the PE RVUs for CPT code 99232 will be 0.60, even though as the Agency noted above, payment for subsequent hospital component codes is supposed to be bundled into the payment for inpatient dialysis. Thus, the PE RVUs for inpatient dialysis will be less than that of its component code.
CMS Refinement of Relative Value Units for Hemodialysis Vessel Mapping Services
RPA therefore urges CMS to revise the fully implemented practice expense values for the inpatient dialysis code family to ensure that they are not less than that of its component code.
In the proposed rule for the 2012 fee schedule, CMS discussed a list of G-codes that were to have their PE RVUs adjusted to reflect Medicare Economic Index (MEI) rebasing and revising, and was proposing to implement these adjustments in 2012 to develop more accurate payment rates for these services relative to other fee schedule services. Service code G-0365 (Vessel mapping of vessels for hemodialysis access) was among the codes on this list, and as a result of the adjustment, the total RVUs for G-0365 were to be reduced by over 17%.
RPA and other groups expressed concern regarding this reduction, due to the critically important role that vessel mapping services plays in the successful creation of arteriovenous (AV) fistulae. Successful AV fistula placement is an element of sufficient consequence that CMS itself is a leading partner in the Fistula First Breakthrough Initiative (FFBI) program, whose mission is to promote the use of AV fistulae. In the final rule, CMS has reversed the proposed reduction in PE RVUs for service code G-0365, and rather than the service having a total RVU reduction of over 17%, the total RVUs for the service are now slated to be increased by over 5%.
RPA commends CMS for its flexibility in acknowledging a proposed RVU change that would not benefit the common good of the Medicare program and its beneficiaries, and the Agency’s foresight in promptly reversing the proposed change.
As always, RPA welcomes the opportunity to work collaboratively with CMS in its efforts to improve the quality of care provided to the nation’s kidney patients, and we stand ready as a resource to CMS in its future endeavors. Any questions or comments regarding this correspondence should be directed to RPA’s Director of Public Policy, Rob Blaser, at 301-468-3515, or by email at firstname.lastname@example.org
Ruben L. Velez, MD