January 2, 2001
Robert Berenson, MD
Acting Deputy Administrator
Health Care Financing Administration
Department of Health and Human Services
P.O. Box 8013
Baltimore, MD 21244
Re: HCFA-1120-FC—Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule for Calendar Year 2001
Dear Dr. Berenson:
On behalf of the American Urological Association (AUA), representing 9,200 American urologists, I am pleased to submit comments on the final rule implementing changes for 2001 to the Medicare physician fee schedule.
Zero Work Pool Changes for Urology Codes
We applaud HCFA for changing the methodology used to calculate practice expense relative value units (RVUs) for the technical component portion of certain urodynamics and penis procedures that are performed mostly by urologists. In our September 15, 2000 comments on HCFA's proposed changes to the 2001 Medicare physician fee schedule, the AUA pointed out that the zero work pool methodology was being used to calculate the technical component practice expense RVUs for 12 such services.
This means that for procedures mostly performed by urologists, the practice expense RVUs were being calculated using the all physician practice expense per hour rather than the urology practice expense per hour. By placing these codes back into urology's practice expense pool, HCFA has calculated values for the codes that more accurately reflect the actual costs associated with performing these procedures. We realize the zero work pool is an interim solution to this problem with the practice expense methodology and look forward to HCFA's recommendations in the future for developing practice expense RVUs for codes with no work values.
Refinement of Practice Expense Inputs for E&M Services
As active participants in the practice expense refinement process, we strongly support HCFA's acceptance of the PEAC/RUC recommended refinements to the 15 major evaluation and management codes. The refined inputs for these codes reflect the work of a multi-disciplinary workgroup employing a fair and deliberate process. This represents a major positive step towards consolidating and streamlining practice expense inputs, and we would strongly oppose any effort to revert back to previous methodologies used for setting practice expense payments for these codes.
Work Relative Value Units (RVUs) for Cryosurgical Ablation of the Prostate
The AUA strongly disagrees with HCFA's acceptance of the RUC's recommended work value of 17.8 for CPT® code 55873, Cryosurgical ablation of the prostate (includes ultrasonic guidance for interstitial cryosurgical probe placement).
This work RVU does not reflect the total work involved in this complex and demanding cancer surgery, and improper comparisons were made to services treating benign prostate disease in the establishment of this value. The comparison to CPT® code 55801, Prostatectomy, perineal, subtotal (including control of postoperative bleeding, vasectomy, meatotomy, urethral calibration and/or dilation, and internal urethrotomy) was inappropriate to set cryosurgery's RVW and as a result we will have the RUC review this issue at its February 2001 meeting.
In addition, if the outcome of the second RUC review of this procedure does not satisfactorily resolve this problem, we hope HCFA will review the code at its next refinement panel meeting. Last year, HCFA convened a multispecialty panel of physicians to assist in the review of comments on disputed work RVUs, including a code disputed by the AUA-CPT code 76873, Prostate volume study. We participated in this process and were pleased with the outcome of the review. Also, we appreciate that HCFA has reinstated this process, which was used in the past but had not been utilized for some time.
HCFA's National Coverage Decision on Clinical Trials
In June 2000, President Clinton requested that the Secretary of HHS develop a policy to facilitate Medicare coverage of the routine health care costs associated with beneficiaries' participation in clinical trials. HCFA subsequently released a national coverage decision in September 2000 on Medicare coverage for clinical trials.
Because this coverage decision has the potential to cause an increase in the number of physician visits paid for under Medicare, which will in turn cause a growth in spending for physician services, it is important that HCFA have a mechanism to incorporate these changes into updates to the sustainable growth rate (SGR). Otherwise, future payment updates to the Medicare physician fee schedule would not accurately reflect changes in spending for physician services due to changes in laws and regulations.
Thank you for considering our comments. If you have any questions, please contact Robin Hudson, Manager of Regulatory Affairs, at 410-689-3762 or govaffairs@AUAnet.org.
Irwin N. Frank, MD, F.A.C.S.
American Urological Association
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