AUA’S COMMENT

FINAL RULE PROVISION

CMS did not address any specific comments in the final rule but was appreciative of comments from all stakeholders.

- Supported AMA RUC recommended, and CMS proposed work RVUs for intra-abdominal tumor excision and destruction services for CPT codes 49186, 49187, and 49188.

- Recommended CMS accept AMA RUC recommended work RVUs for CPT codes 49189 and 49190. CMS proposed work RVUs that were 5 RVUs lower than the RUC recommended values.

CMS finalized, as proposed work RVUs 49186, 49187, 49189, 49188, and 49190.

Supported the CMS proposed RVUs for bladder neck and prostate procedures, CPT codes 53865 and 53866.

CMS finalized RVUs as proposed and increased the supply price for the iTind device from $2695.00 to $2972.50 after receiving additional invoices during the comment period.   

- Encouraged CMS to accept as proposed the RVUs for MRI-Monitored Transurethral Ultrasound Ablation of Prostate (CPT codes 51721, 55881, and 55882).

- Recognized the survey respondents lack of experience with the service.

CMS finalized RVUs as proposed and agrees with comments that the services will benefit from a review in three years as the codes are on the new technology code list.

Supported CMS policy to not pay for the new telemedicine E/M codes and supported policy to use the current set of E/M codes with the appropriate modifiers to describe E/M services provided via telemedicine.

This policy was finalized. However, CMS will make payment for one of the new codes, 98016 (brief communication technology-based service (e.g., virtual check-in), and will delete G2012 which was used to report a similar service.

Supported allowing distant site practitioners to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.

This policy was finalized.

- Recommended CMS phase-in results of the AMA PPIS to avoid destabilizing payment cuts.

- Encouraged CMS to review and update indirect and direct PE inputs at regular intervals to support accurate valuation of physician services

CMS did not implement any policy but will take comments received into consideration in future rule making.

To avoid a significant cut to reimbursement for urology services, requested that CMS phase-in the revised supply pack price for the urology cystoscopy visit supply pack and supply pack for drapes used in cystoscopy.

CMS accepted the recommendation to phase-in the supply pack for the urology cystoscopy visit supply pack. The agency will phase-in the new value over a four-year period. However, the supply pack for cystoscopy drapes in only included in seven CPT codes, therefore CMS will not phase-in this decrease.

Note that CMS will also phase-in the increased price of the supply pack, cleaning and disinfecting, endoscope.

Recommended delay of the proposal to require use of modifiers for transfers of care (-54, -55, -56) for 90-day global surgical codes.

CMS finalized the use of modifier -54 (surgical care only) to indicate instances for 90-day global surgical packages when a practitioner plans to furnish only the surgical procedure portion of the global package (including both formal and other transfers of care).” No change in policy was implemented for -55, and -56.

Supported updating the Medicare Claims Processing Manual (MCPM) to modify the coding language to match the CPT code book for non-chemotherapeutic complex drug administration.  

CMS will update the MCPM to clarify coding guidelines for the administration of non-chemotherapeutic complex drugs. CMS will use the existing coding guidelines and constructs outlined in the CPT code book.