January 3, 2005
Mark McClellan, MD, PhD
Department of Health and Human Services
Centers for Medicare & Medicaid Services
P.O. Box 8012
Baltimore, MD 21244-8012
RE: CMS-1429-FC: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule for Calendar Year 2005
Five Year Refinement of Work Relative Value Units for Calendar Year 2004
The American Urological Association (AUA) requests that CPT® code 51798, Measurement of post-voiding residual urine and/or bladder capacity by ultrasound, non-imaging be assigned 0.38 work RVUs. CPT® code 51798 was surveyed by the AUA and presented to the American Medical Association's (AMA) Relative Value Update Committee (RUC) in April 2002. The survey found that urologists typically perform this procedure and the AUA recommended a work value of 0.58.
The RUC reviewed the AUA's request and noted that the most appropriate reference code was CPT® code 76857, Ultrasound, pelvic (nonobstetric), B-scan and/or real time with image documentation; limited or follow-up (eg, for follicles) (Work RVU=0.38) rather than CPT® code 76942, Ultrasonic guidance for needle placement (eg, biopsy, aspiration, injection, localization device), imaging supervision and interpretation (Work RVU=0.67).
Based on the AUA's 25th percentile survey results and the similarities in work of codes 76857 and 51798, the RUC recommended a relative work value of 0.38, and physician time equal to the AUA's surveyed 25th percentile. When the RUC recommendation for a work value of 0.38 was submitted to CMS, in spite of the survey results that indicated many physicians performed this procedure, CMS did not assign physician work to CPT® code 51798. The AUA requests that the RUC recommendation be reaffirmed and that 0.38 work RVUs be assigned to CPT® code 51798.
Thank you for considering our comments. If you have any questions or need additional information, please contact John Ridge, AUA Reimbursement Systems Manager, at 410-689-3780 or jridge@AUAnet.org.
Brendan M. Fox, MD
CPT® is a registered trademark of the American Medical Association.