AMA/SPECIALTY SOCIETY RVS UPDATE PROCESS RUC RECOMMENDATIONS FOR CPT 2018 INTRODUCTORY MATERIALS TABLE OF CONTENTS RUC Cover Letter 1 HCPAC Cover Letter 2 RUC and HCPAC Recommendations Status Report: New and Revised Codes 3 RUC and HCPAC Recommendations for Existing Codes 4 RUC Relativity Assessment Workgroup Progress Report 5 CMS Requests and Relativity Assessment Workgroup Status Report 6 RUC Referrals to CPT Editorial Panel 7 RUC Recommendations to Develop CPT Assistant Articles 8 New Technology/New Services List 9 New Technology/Services Timeline 10 Specialty and Acronym List 11 February 6, 2017 Carol Blackford Director Hospital and Ambulatory Policy Group Center for Medicare Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850 Subject: RUC Recommendations Dear Ms. Blackford: The American Medical Association (AMA)/Specialty Society RVS Update Committee (RUC) submits the enclosed recommendations for work relative values and direct practice expense inputs to the Centers for Medicare and Medicaid Services (CMS). These recommendations relate to new and revised codes for CPT 2018, as well as to existing services identified by the RUC’s Relativity Assessment Workgroup and CMS. Enclosed are the RUC recommendations for all the CPT codes reviewed at the January 11-14, 2017 RUC meeting. CPT 2018 New and Revised Codes – January 2017 RUC Submission The enclosed binder contains RUC recommendations, including those for new and revised CPT codes. The RUC considered 108 new/revised/related family CPT codes at the January 2017 meeting. The RUC submits work value and/or practice expense inputs for 108 new/revised/related family CPT codes from the January meeting. CPT 2018 New and Revised Codes – Entire CPT 2018 Cycle The total number of coding changes for the entire CPT 2018 cycle is 349, including 151 additions, 63 revisions, and 97 deletions. In addition, 38 new codes were identified as part of the family for review in relationship to the new/revised codes. The 260 new/revised/related family CPT codes are summarized as follows: • 93 services are not payable on the RBRVS or do not require physician work at this time (eg, laboratory services and vaccines), and accordingly, the RUC does not submit any information on these codes. • The HCPAC submits recommendations for 4 new/revised CPT codes. The RUC submits work value and/or practice expense inputs for 155 new/revised/related family CPT codes for the 2018 Medicare Physician Payment Schedule. Carol Blackford February 6, 2017 Page 2 Existing Services Identified by RUC and CMS for Review In addition to the new/revised CPT code submission, the RUC submits recommendations for 21 services identified by the RUC or CMS as potentially misvalued and reviewed at the January 2017 RUC meeting. The RUC recommends work relative values for 19 codes and direct practice expense inputs only for 2 codes. These recommendations are in addition to the 99 recommendations for existing services submitted to CMS following the RUC’s April and October 2016 meetings. RUC Progress in Identifying and Reviewing Potentially Misvalued Codes Since 2006, the RUC has identified 2,246 potentially misvalued services through objective screening criteria and has completed review of 2,098 of these services. The RUC has recommended that over half of the services identified be decreased or deleted (Figure 1). The RUC has worked vigorously over the past several years to identify and address misvaluations in the RBRVS through provision of revised physician time data and resource recommendations to CMS. The RUC looks forward to working with CMS on a concerted effort to address potentially misvalued services. A detailed report of the RUC’s progress is appended to this letter. Figure 1: AMA/Specialty Society RVS Update Committee (RUC) Potentially Misvalued Services Project 7% Codes under Review, 149, 7% 27% 17% Deleted, 393, 17% Decreased, 905, 40% 9% Increased, 202, 9% 40% Reaffirmed, 598, 27% CMS 000-Day Global Services Reported with an E/M with Modifier 25 In the NPRM for 2017 CMS identified 83 services with a 000-day global period billed with an E/M 50 percent of the time or more, on the same day of service, same patient, by the same physician, that have not been reviewed in the last five years with Medicare utilization greater than 20,000. The RUC commented that it appreciated CMS’ identification of an objective screen and reasonable query. However, based on further analysis of the codes identified, it appears only 19 services met the criteria for Carol Blackford February 6, 2017 Page 3 this screen and have not been reviewed to specifically address an E/M performed on the same date. There were 38 codes that did not meet the screen criteria; they were either reviewed in the last 5 years and/or are not typically reported with an E/M. For 26 codes, the summary of recommendation (SOR), RUC rationale or practice expense inputs submitted specifically states that an E/M is typically reported with these services and the RUC accounted for this in its valuation. The RUC requested that CMS remove 64 services that did not meet the screen criteria or which have already been valued as typically being reported with an E/M service. The RUC requested that CMS condense and finalize the list of services for this screen to the 19 remaining services. In the Final Rule for 2017, CMS did finalize the list of 000-day global services reported with an E/M to the 19 services that truly met the criteria. In January 2017, AAOS, ASSH and APMA noticed that the RUC database did not have the vignette shown for CPT code 20612, but instead the intra-service work was inserted in the vignette cell. Upon review of the summary of recommendation for 20612, and in addition code 20526 which was also on the CMS list, both presented at the April 2002 meeting, the specialty societies discovered that in fact an E/M as typical was considered in the survey process; the survey vignettes had a "note" directing the survey respondents to NOT include E/M work when completing the survey. The specialty societies recommend and the RUC agreed that CPT codes 20612 and 20526 should be removed from this screen since the valuation for these services already excludes any E/M with this service. The RUC recommends that CMS remove codes 20612 and 20526 from this screen and the RUC database be revised to include the correct vignettes for codes 20612 and 20526. The original summary of recommendation forms are attached to this letter. The RUC will review the remaining 17 services for the 2019 Medicare Physician Payment Schedule. Practice Expense Subcommittee The attached materials include direct practice expense input (clinical staff time, supplies and equipment) recommendations for each code reviewed. In addition to recommendations related to the specific CPT codes under review, the RUC is submitting products of the Scope Equipment and Supplies Workgroup, including analysis of all scope equipment and supplies included in the 2016 direct practice expense inputs. A Workgroup of the Practice Expense (PE) Subcommittee was formed to review the proposed pricing structure that separated out the components for scopes, scope video systems, and scope accessories as outlined by CMS in the Proposed Rule for CY2017. CMS finalized the proposal, without offering to delay pending input from the Workgroup, so the Workgroup is simply sharing the analysis at this time. The RUC is also submitting a recommendation regarding extended monitoring equipment and oxygen as a supply item. A workgroup of the Practice Expense (PE) Subcommittee was formed to review the standard equipment related to non-moderate sedation post-procedure monitoring. The Workgroup also discussed the issue of the proper allocation of oxygen for services done with moderate sedation. There are a very limited number of services with oxygen as a supply item; however the stand alone moderate sedation codes do not include oxygen in the supplies. The Workgroup identified 26 services that include oxygen. The recommended equipment items as well as a table listing the 26 codes that include oxygen and the rationale for maintenance or deletion is included in this submission. Separate Payment for High Cost Medical Supplies Carol Blackford February 6, 2017 Page 4 The RUC has repeatedly called on CMS to separately identify and pay for high cost disposable supplies using distinct J codes, rather than bundle into the service described by CPT so that these expenses may be monitored closely and paid appropriately. There are approximately 33 supply items that CMS has priced in excess of $1,000, for example. The RUC urges CMS to establish J codes for high cost supplies. The pricing of these supplies should be based on a transparent process, where items are annually reviewed and updated. Enclosed Recommendations and Supporting Materials: Included in these binders and on the enclosed CD are: • RUC Recommendation Status Report for New and Revised Codes • RUC Recommendation Status Report for 2,246 services identified to date by the Relativity Assessment Workgroup and CMS as potentially misvalued. In addition, a spreadsheet containing the codes specific to this submission is included. • RUC Referrals to the CPT Editorial Panel – both for CPT nomenclature revisions and CPT Assistant articles. • Physician Time File: A list of the physician time data for each of the CPT codes reviewed at the January 2017 RUC meeting. • Pre-Service and Post-Service Time Packages Definitions: The RUC developed physician pre- service and post-service time packages which have been incorporated into these recommendations. The intent of these packages is to streamline the RUC review process as well as create standard pre-service and post-service time data for all codes reviewed by the RUC. • PLI Crosswalk Table: The RUC has committed to selecting appropriate professional liability insurance crosswalks for new and revised codes and existing codes under review. We have provided a PLI Crosswalk Table listing the reviewed code and its crosswalk code for easy reference. We hope that the provision of this table will assist CMS in reviewing and implementing the RUC recommendations. • BETOS Assignment Table: The RUC, for each meeting, provides CMS with suggested BETOS classification assignments for new/revised codes. Furthermore, if an existing service is reviewed and the specialty believes the current assignment is incorrect, this table will reflect the desired change. • Source Code Utilization Crosswalk Table: A table estimating the flow of claims data from existing codes to the new/revised codes. This information is used to project the work relative value savings to be included in the 2018 conversion factor increase. Carol Blackford February 6, 2017 Page 5 • New Technology List and Flow Chart: In April 2006, the RUC adopted a process to identify and review codes that represent new technology or services that have the potential to change in value. To date, the RUC has identified 541 of these procedures through the review of new CPT codes. A table of these codes identified as new technology services and the date of review is enclosed, as well as a flow chart providing a detailed description of the process to be utilized to review these services. We appreciate your consideration of these RUC recommendations. If you have any questions regarding the attached materials, please contact Sherry Smith at (312) 464-5604. Sincerely, Peter K. Smith, MD Enclosures cc: Isadora Gil Edith Hambrick, MD Ryan Howe Karen Nakano, MD Michael Soracoe Marge Watchorn RUC Participants February 6, 2017 Carol Blackford Director Hospital and Ambulatory Policy Group Center for Medicare Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850 Dear Ms. Blackford: The RUC Health Care Professionals Advisory Committee (HCPAC) Review Board submits the enclosed recommendation to the Centers for Medicare and Medicaid Services (CMS). At the January 2017 meeting, the HCPAC reviewed five issues • Cognitive Function Intervention (97X11) • Psychological and Neuropsychological Testing (96105, 96125, 963X0, 963X3, 963X5) • Physical Medicine and Rehabilitation Services (97010, 97012, 97014, 97016, 97018, 97022, 97032-35, 97110, 97112, 97113, 97116, 97140, 97530, 97533, 97535, 97537, 97542, G0283) • Orthotic Management and Prosthetic Training (97760-61, 977X1), • Application of Surface Neurostimulator (64550). The RUC and HCPAC are fully committed to this ongoing effort to improve relativity in the work, practice expense, and professional liability insurance values. The HCPAC appreciates the opportunity to provide recommendations related to the 2018 Medicare Physician Payment Schedule. If you have any questions regarding this submission, please contact Samantha Ashley (ph: 312-464-4720; email: [email protected]) at the AMA for clarification regarding these recommendations. Sincerely, Michael D. Bishop, MD HCPAC Chair Jane V. White, PhD, RD, FADA, LDN HCPAC Co-Chair cc: Isadora Gil Edith Hambrick, MD Ryan Howe Karen Nakano, MD Michael Soracoe Marge Watchorn HCPAC Participants CPT 2018 RUC and HCPAC Recommendations CPT Global Coding CPT CPT Issue Tracking RUC RUC S.S. Specialty RUC Rec Same RVU as MFS? Comments New Code Period Change Date Tab Number Date Tab Rec last year? Tech/Service 0001U XXX N Feb17 62 PLA Q1 Codes CLFS 0002U XXX N Feb17 62 PLA Q1 Codes CLFS 0003U XXX N Feb17 62 PLA Q1 Codes CLFS 0004U XXX N Feb17 62 PLA Q1 Codes CLFS 0005U XXX N Feb17 62 PLA Q1 Codes CLFS 0051T XXX D Oct16 26 Artificial Heart Jan17 09 STS, AATS System Procedures 0052T XXX D Oct16 26 Artificial Heart Jan17 09 STS, AATS System Procedures 0053T XXX D Oct16 26 Artificial Heart Jan17 09 STS, AATS System Procedures 00740 XXX D Oct16 12 Anesthesia for GI Jan17 04 ASA Procedures 00731 XXX N Oct16 12 Anesthesia for GI N1 Jan17 04 ASA 5.00 5.00 Procedures 00732 XXX N Oct16 12 Anesthesia for GI N2 Jan17 04 ASA 6.00 6.00 Procedures 00810 XXX D Oct16 12 Anesthesia for GI Jan17 04 ASA Procedures 00811 XXX N Oct16 12 Anesthesia for GI N3 Jan17 04 ASA 5.00 4.00 Procedures 00812 XXX N Oct16 12 Anesthesia for GI N4 Jan17 04 ASA 4.00 4.00 Procedures 00813 XXX N Oct16 12 Anesthesia for GI N5 Jan17 04 ASA 6.00 5.00 Procedures 01180 XXX D Oct16 101 Code Set Deleted Maintenance 01190 XXX D Oct16 101 Code Set Deleted Maintenance 01682 XXX D Oct16 101 Code Set Deleted Maintenance 0178T XXX D Feb16 43 Category III Cat III Sundown Monday, September 25, 2017 Page 1 of 24 CPT Global Coding CPT CPT Issue Tracking RUC RUC S.S. Specialty RUC Rec Same RVU as MFS? Comments New Code Period Change Date Tab Number Date Tab Rec last year? Tech/Service 0179T XXX D Feb16 43 Category III Cat III Sundown 0180T XXX D Feb16 43 Category III Cat III Sundown 0492T ZZZ N June17 37 Category III Ablative Cat III Laser Wound Treatment 0494T XXX N June17 41 Category III Donor Cat III Lung Assessment and Perfusion 0495T XXX N June17 41 Category III Donor Cat III Lung Assessment and Perfusion 0496T XXX N June17 41 Category III Donor Cat III Lung Assessment and Perfusion 0497T XXX N June17 45 Category III Mobile Cat III External ECG Event Recording Services 0498T XXX N June17 45 Category III Mobile Cat III External ECG Event Recording Services 0479T XXX N Feb17 41 Ablative Laser Cat III Treatment of Burn Scars 0254T XXX R Oct16 27 Endovascular Jan17 10 SVS, SIR, Repair Procedures STS, AATS (EVAR) 0255T XXX D Oct16 27 Endovascular Jan17 10 SVS, SIR, Repair Procedures STS, AATS (EVAR) 0493T XXX N June17 34 Category III Near- Cat III Infrared Spectroscopy 0293T XXX D Feb16 43 Category III Cat III Sundown 0294T XXX D Feb16 43 Category III Cat III Sundown 0299T XXX D Feb16 43 Category III Cat III Sundown Monday, September 25, 2017 Page 2 of 24 CPT Global Coding CPT CPT Issue Tracking RUC RUC S.S. Specialty RUC Rec Same RVU as MFS? Comments New Code Period Change Date Tab Number Date Tab Rec last year? Tech/Service 0499T XXX N June17 43 Category III Urethral Cat III Therapeutic Drug Delivery 0500T XXX N June17 39 Category III HPV Cat III Extended Genotyping 0501T XXX N June17 40 Category III Cat III Noninvasive Estimated Coronary Fractional Flow Reserve 0502T XXX N June17 40 Category III Cat III Noninvasive Estimated Coronary Fractional Flow Reserve 0503T XXX N June17 40 Category III Cat III Noninvasive Estimated Coronary Fractional Flow Reserve 0504T XXX N June17 40 Category III Cat III Noninvasive Estimated Coronary Fractional Flow Reserve 0480T XXX N Feb17 41 Ablative Laser Cat III Treatment of Burn Scars 0300T XXX D Feb16 43 Category III Cat III Sundown 0301T XXX D Feb16 43 Category III Cat III Sundown 0302T XXX D Feb16 43 Category III Cat III Sundown 0303T XXX D Feb16 43 Category III Cat III Sundown 0304T XXX D Feb16 43 Category III Cat III Sundown 0305T XXX D Feb16 43 Category III Cat III Sundown Monday, September 25, 2017 Page 3 of 24