AUA Comments

Final Rule Provision

Conversion Factor

Appreciated the positive updates to the two conversion factors but pointed to the potential negative impact (on physician payment) when combined with the proposed efficiency adjustment and changes to practice expense payment for services in the facility setting.

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

Updates to the Practice Expense

Urged CMS not to finalize the proposed cut to facility-based indirect PE RVUs and recommended delaying implementation by one year to collect empirical data and develop a revised methodology.

Emphasized that physicians in facility settings still incur significant indirect costs such as rent, staffing, and administrative overhead. Noted that some urologists employed by hospitals also pay rent for both facility and non-facility-based clinics.

CMS finalized policy that will recognize greater indirect costs for practitioners in office-based settings compared to facility settings. Therefore, indirect practice expense will be cut by 50% for services performed in the facility setting.

CMS noted that while it has previously phased in major PE methodology changes, a multi‑year transition would reduce increases intended for non‑facility services and prolong existing site‑of‑service payment disparities, especially since fewer than half of practitioners own their practices.

Proposed Valuation of Specific Codes for CY 2026    

CPT Code 52649: The AUA urges CMS to accept the RUC recommended work RVU of 14.56 (not the CMS recommendation of 13 RVUs based on a crosswalk to CPT code 53500). 

AUA believes the current value of 14.56 appropriately values this service using magnitude estimation compared to services within this family and strongly disagrees with the crosswalk of 53500, noting that 52649 is a significantly more intense procedure than 53500.

CMS did not agree with the AUA citing that the significant decrease in time should be reflected in a decrease to the work RVU and that maintaining the current RVU of 14.56 would place the code out alignment with the rest of the code family.

CPT Code 55867: Supports the proposed PE changes and the resulting changes to the work for CPT Code 55867.

CMS finalized its proposed PE changes, which the AUA supported.

CPT Code 52XX2: The AUA requested the reconsideration of the following PE inputs for CPT Code 52XX2.

• CA023 (Clinical Staff Time – add 5 minutes of non-multi-tasking monitoring)
• CA025 (Equipment Cleaning – Additional 10 minutes): We request CMS maintain the additional 10 minutes above the standard 30-minute cleaning time to reflect the dual equipment use during this procedure.
• SM022 (Sanitizing Wipes – Surfaces/Equipment): SM022 is appropriately included for surface and equipment cleaning at the conclusion of the procedure and therefore should be retained as a PE input. Four sanitizing wipes are required to wipe down all surfaces and equipment involved in care delivery, including the patient bed, equipment tables, and ultrasound equipment.
• SM021 (Sanitizing Wipe – Patient): In addition to the five wipes already included in the standard cystoscopy pack for patient cleaning, one additional wipe (SM021) is required for this service. This is due to the need to insert a transrectal ultrasound probe, which requires cleaning of the peri-rectal area. This step is not typically required for standard cystoscopy procedures and should be included as a PE input.

• CA023: CMS appreciated the additional information provided regarding the clinical activities associated with CA023 and agrees that 5 minutes would be more appropriate to closely monitor for bleeding, uncontrolled pain and other post-procedural complications, therefore, CMS finalized the RUC-recommended 5 minutes for CA023 for CPT code 52443.
• CA025: CMS appreciate the additional information provided about the second scope to support the need for 10 minutes beyond the standard 30 minutes for CA025 for CPT code 52443 and noted that 10 minutes of CA025 conforms with CMS’ standard cleaning time for a rigid scope, such as a transrectal ultrasound probe. Therefore, CMS finalized 40 minutes total of clinical activity time for CA025 for CPT code 52443 to account for the 30 minutes to clean ES018 and 10 minutes to clean the transrectal ultrasound probe.
• SM022 and SM021: CMS is not finalizing their proposed refinement and instead is finalizing the RUC recommended inclusion of a single SM021 supply, due to the use of the transrectal ultrasound probe which requires an additional cloth wipe for the patient.

Proposed Efficiency Adjustment

Opposed the principle of applying an efficiency adjustment across procedures. Recommended exempting codes valued within the past ten years and delaying implementation until robust data sources are available. Opposed equating surgical efficiency with speed and urged CMS to consider new, nuanced approaches that account for all phases of care.

If this policy is finalized, AUA recommended that codes valued within the last ten years be exempted from this adjustment.

Asked CMS to delay implementation until inclusive and robust data sources are available.

Recommended CMS adopt a more nuanced approach to measuring physician efficiency, using new data sources on physician time and studies that account for all phases of care, not just intraoperative time.

CMS finalized the negative 2.5% efficiency adjustment to the work RVUs and intraservice time for nearly all services on the MPFS including procedures, radiology services, and diagnostic tests. The agency will exempt codes new for CY 2026 from the efficiency adjustment for CY 2026.

CMS welcomed empiric data to support the value of physician services, which is yet another indication that CMS does not want to rely solely on RUC survey data to set payment rates.

Global Surgery Payment Accuracy

Cautioned CMS against undervaluing post-operative work and requested reimbursement for the time spent managing electronic communications.

Encouraged CMS to focus on providing better education to ensure appropriate use of modifiers and analyze claims data to determine the prevalence of these situations before implementing broad policy changes that could harm urologists and patient access to urologic care.

CMS appreciated the comments. No payment methodology changes were finalized; Providers must still report modifier -54 and G0559 as applicable.

Software as a Service (SaaS) and Artificial Intelligence Tools

Urged CMS to value software-based tools cautiously to preserve physician oversight and reflect clinical realities. Recommended including SaaS as part of the practice expense rather than as a separately billable service.

CMS appreciated feedback and may consider for future rulemaking.