PRACTICE RESOURCES > Regulation/AUA Positions, Letters, and Talking Points > ASC Letter to CMS


ASC Letter to CMS

October 14, 2002

Ms. Joan Sanow
Department of Health and Human Services
Center for Medicare and Medicaid Services
MS C4-03-18
7500 Security Boulevard
Baltimore MD 21244-1850


Dear Ms. Sanow:

On behalf of the American Urological Association (AUA) and its 10,000 members, I am writing in anticipation of a final rule on the ambulatory surgical center (ASC) payment system soon to be published by the Centers for Medicare and Medicaid Services (CMS). As we understand it, this rule would finalize parts of the June 12, 1998 proposed rule-HCFA-1885-P. For your information, I have included a copy of the AUA's proposed-rule comments.

We understand that the final rule will deal only with the addition and deletion of CPT® codes from the Medicare ASC list of covered services, and will not address payment rates. We agree that there are many procedures that should be added to the ASC list, but are disappointed with CMS's policy decision to determine whether to add or delete CPT® codes from the ASC list outside the context of proper payment.

With these constraints in mind, we offer the following recommendations for the ASC list. These recommendations are based on which procedures can be safely and effectively performed in an ASC and which ones would actually be performed in an ASC considering the current nine payment groups. CMS should not place procedures on the ASC list if they cannot be adequately reimbursed in an ASC, as this really accomplishes nothing. Because of this, we urge CMS to begin paying for ASC services using the ambulatory payment classification system (as proposed in 1998) as soon as possible.

We offer three categories of CPT® codes for your consideration:

  1. CPT® codes that have been created since 1998 that should be on the ASC list
  2. CPT® codes that have been created since 1998 that should not be on the ASC list until the payment system is adjusted
  3. CPT® codes that were proposed to be added to the ASC list in 1998 that should not be on the list until the payment system is adjusted

1. CPT® codes that have been created since 1998

Table I shows procedures that have received a new CPT® code since release of the June 12, 1998 proposed rule that can be safely and effectively performed in an ASC and that could be reimbursed adequately using the current nine payment groups.

CPT® Code

Descriptor

Globe

New In…

11981

Insertion, non-biodegradable drug delivery implant

XXX

2002

11982

Removal, non-biodegradable drug delivery implant

XXX

2002

11983

Removal with reinsertion, non-biodegradable drug delivery implant

XXX

2002

54406

Removal of all components of a multi-component, inflatable penile prosthesis w/o replacement of prosthesis

90

2002

54415

Removal of non-inflatable (semi-rigid) or inflatable (self-contained) penile prosthesis, w/o replacement of prosthesis

90

2002

54522

Orechiectomy, Partial

90

2001


2. CPT® codes that have been created since 1998 that should not be on the ASC list until the payment system is adjusted

Table II shows procedures that have received a new CPT® code since release of the June 12, 1998 proposed rule that could be safely and effectively performed in an ASC. While we agree conceptually that these services can be performed in ASC settings, the proposed payment levels are grossly inadequate. In fact, for a number of procedures, the current ASC payment rates will not cover the cost of the disposable supplies. Unless the payment rate is substantially increased, these procedures will not be performed in an ASC setting. Therefore, it makes little sense to add these procedures to the ASC list until such time as the ASC payment rates are revised to provide for payment substantially above the current rate assigned to Group nine services.

CPT® Code

Descriptor

Globe

New In…

50021

Drainage of perirenal or renal abscess; Percutaneous

0

1998

50949

Unlisted laparoscopy procedure, ureter

YYY

2001

51990

Laparoscopy, surgical; urethral suspension for stress incontinence

90

2000

51992

Laparoscopy, surgical; sling operation for stress incontinence (eg, fascia or synthetic)

90

2000

52341

Cystourethroscopy with treatment of ureteral stricture (eg, balloon dilation, laser, electrocautery, and incision)

0

2001

52342

Cystourethroscopy with treatment of ureteropelvic junction stricture (eg, balloon dilation, laser, electrocautery, and incision)

0

2001

52343

Cystourethroscopy with treatment of intra-renal stricture (eg, balloon dilation, laser, electrocautery, and incision)

0

2001

52344

Cystourethroscopy with ureteroscopy; with treatment of ureteral stricture (eg, balloon dilation, laser, electrocautery, and incision)

0

2001

52345

Cystourethroscopy with ureteroscopy; with treatment of ureteropelvic junction stricture (eg, balloon dilation, laser, electrocautery, and incision)

0

2001

52346

Cystourethroscopy with ureteroscopy; with treatment of intra-renal stricture (eg, balloon dilation, laser, electrocautery, and incision)

0

2001

52347

Cystourethroscopy with transurethral resection or incision of ejaculatory ducts

0

2002

53853

Transurethral destruction of prostate tissue; by water-induced thermotherapy, 090: proposed

90

2002

54408

Repair of component(s) of a multi-component, inflatable penile prosthesis

90

2002

54410

Removal and replacement of all component(s) of a multi-component, inflatable penile prosthesis at the same operative session

90

 

 

CPT® Code

Descriptor

Globe

New In…

54416

Removal and replacement of non-inflatable (semi-rigid) or inflatable (self-contained) penile prosthesis at the same operative session

90

2002

54690 (formerly 56318)

Laparoscopy, surgical; orchiectomy

90

2000

54699

Unlisted laparoscopy procedure, testis

YYY

2000

55550

Laparoscopy, surgical, with ligation of spermatic veins for varicocele

90

2000

55559

Unlisted laparoscopy procedure, spermatic cord

YYY

2000

55873

Cryosurgical ablation of the prostate (includes ultrasonic guidance for interstitial cryosurgical probe placement)

90

2001

57287

Removal or reversal of sling for stress incontinence (eg, fascia or synthetic)

90

2001

64561

Percutaneous implantation of neurostimulator electrodes; sacral nerve (transforaminal placement)

10

2002

64581

Incision for implantation of neurostimulator electrodes; sacral nerve (transforaminal placement)

10

2002


3. CPT® codes that were proposed to be added to the ASC list in 1998 that should not be on the list until the payment system is adjusted

Table III shows three CPT® codes that were proposed to be added to the ASC list in 1998, but that also will not be performed in an ASC under the current nine payment groups. In fact, the costs of the disposable supplies alone approximates the entire ASC rate, which is intended to cover clinical and administrative staff costs, supplies, equipment and ASC overhead. Also, these procedures currently have in-office practice expense rates under the physician fee schedule that substantially exceed the highest ASC payment category. We further note that the American Medical Association's Practice Expense Advisory Committee is going to be validating the practice expenses for these three codes in the next few months. We urge CMS not to add these codes to the ASC list since the procedures will not be performed in that setting at current rates. Rather, you may want to consider the PEAC's determination of costs for future consideration of appropriate ASC rates for these services.

CPT® Code

Descriptor

52647

Non-contact laser coagulation of prostate, including control of postoperative bleeding, complete (vasectomy, meatotomy, cystourethroscopy, urethral calibration and/or dilation, and internal urethrotomy are included)

53850

Transurethral destruction of prostate tissue; by microwave thermotherapy

53852

Transurethral destruction of prostate tissue; by radiofrequency thermotherapy


Thank you for considering our suggestions for the ASC list. If you have any questions or need additional information, please contact Robin Hudson, Manager of Regulatory Affairs, at 410-689-3762 or govaffairs@AUAnet.org.

Sincerely,

Winston K. Mebust, MD
President
American Urological Association


cc: Bob Cereghino, CMS
William F. Gee, MD, AUA Health Policy Council Chairman
Cherie McNett, AUA Government Affairs Director
 

CPT® is a registered trademark of the American Medical Association.

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