Comments Regarding CPT®
August 30, 2001
The Honorable Tommy G. Thompson
200 Independence Avenue SW
Washington, DC 20201
Letter developed by American College of Chest Physicians, American College of Surgeons and American Urological Association
Dear Secretary Thompson:
The medical organizations listed below are writing to express their strong support for the American Medical Association's Current Procedural Terminology (CPT®) process. Our members represent the physicians who deliver health care in the United States. We are extremely concerned about questions that have been raised about Medicare's use of CPT® without recognizing the considerable benefits that accrue to the health care system and the federal government as a result of the CPT® process. A decision to abandon CPT® would have far-reaching negative consequences for the health care system and the federal government.
CPT® was developed by the American Medical Association and the national medical specialty societies in 1966. The CPT® Editorial Panel, the decision-making group embodied within the CPT® process, enjoys the support and technical expertise of more than 100 medical specialty societies and other health care professional organizations. Between the Editorial Panel and the CPT® Advisors, tens of thousands of hours are volunteered for the betterment of CPT®. It is precisely because of this highly collaborative process that CPT® enjoys such widespread support from the full range of physician specialties, CMS, private payers, and other health care providers. We are extremely skeptical that individuals with appropriate clinical and technical expertise would volunteer the necessary time for other code sets developed by either the government or a corporation.
The development and maintenance of CPT® is a model of public-private sector partnership that is both effective and accountable. It must be continued. The unique editorial process encompassed in CPT® allows for a thorough and open vetting of issues and concerns with all the stakeholders. This public-private sector effort is successful because it uses those who are most qualified to understand and weigh the options to resolve clinical and professional issues which are inherent in making decisions about coding.
Hundreds of thousands of physicians and hospital outpatient departments and virtually all of the major public and private insurers now use CPT®. All have made significant investments in software and other products tied to the CPT®. Just as important, both physicians and payers are familiar with CPT® and its coding conventions. To replace CPT® now would be both costly and disruptive to individual practitioners. Changing to an unfamiliar system is not what is needed at a time when physicians and hospitals are crying out for relief from Medicare's regulatory burden. We urge you to retain the CPT® system, which has proven credentials and credibility.
American Academy of Allergy, Asthma and Immunology
American Academy of Child and Adolescent Psychiatry
American Academy of Dermatology Association
American Academy of Facial Plastic and Reconstructive Surgery
American Academy of Family Physicians
American Academy of Home Care Physicians
American Academy of Neurology
American Academy of Ophthalmology
American Academy of Otolaryngic Allergy
American Academy of Otolaryngology-Head and Neck Surgery
American Academy of Pediatrics
American Academy of Physical Medicine and Rehabilitation
American Association of Clinical Endocrinologists
American Association of Neurological Surgeons
American Association of Orthopaedic Surgeons
American College of Allergy, Asthma and Immunology
American College of Cardiology
American College of Chest Physicians
American College of Clinical Pharmacology
American College of Emergency Physicians
American College of Nuclear Physicians
American College of Obstetricians and Gynecologists
American College of Occupational and Environmental Medicine
American College of Osteopathic Surgeons American College of Physicians
American Society of Internal Medicine
American College of Preventive Medicine
American College of Radiology
American College of Rheumatology
American College of Surgeons
American Diabetes Association
American Gastroenterological Association
American Geriatrics Society
American Medical Group Association
American Osteopathic Association
American Psychiatric Association
American Society for Surgery of the Hand
American Society for Therapeutic Radiology and Oncology
American Society of Anesthesiologists
American Society of Cataract and Refractive Surgery
American Society of Clinical Oncology
American Society of Clinical Pathologists
American Society of Colon and Rectal Surgeons
American Society of General Surgeons
American Society of Hematology
American Society of Neuroradiology
American Society of Plastic Surgeons
American Thoracic Society
American Urological Association
College of American Pathologists
Congress of Neurological Surgeons
Joint Council of Allergy, Asthma and Immunology
Medical Group Management Association
National Association for Medical Direction of Respiratory Care
Renal Physicians Association
Society of Cardiovascular and Interventional
Radiology Society of Critical Care Medicine
Society of Nuclear Medicine
Society of Thoracic Surgeons
The Endocrine Society
cc: William Scanlon
Thomas A. Scully
Laurie Feinberg, MD
Purpose & Process
- The development and maintenance of CPT® is a model of public-private sector partnership that is both effective and accountable.
- The CPT® Editorial Panel consists of physicians and other health care practitioners as well as representatives from the Center for Medicare and Medicaid Services (CMS) and private payers. In addition, there is a representative from the American Health Information Management Association and the Coding Department of the American Hospital Association.
- The Panel meets quarterly in a series of open meetings to keep the system current, consider new technology and procedures, and be responsive to the needs of the provider and payer communities. This process allows for a very thorough vetting of issues and concerns through thoughtful and coordinated discussions and deliberations among these parties. CMS and other payers acknowledge that the open process of considering changes to the CPT® coding system is more public than the government's own process for making changes to its Healthcare Common Procedure Coding System (HCPCS). (That coding system was previously know as the Health Care Financing Administration Common Procedure Coding System.)
- The CPT® Editorial Panel only establishes, modifies, or deletes the codes; the insurers, such as CMS, make the determination whether the service represented by the code will be covered and how much will be paid for the service. Due to the way CMS uses the CPT® coding system, publishing weights for the codes and a dollar amount to use as a multiplier, beneficiaries, providers and physicians can arrive at approximate Medicare reimbursement amounts for given procedures/services. Most other insurers do not reveal reimbursement amount to their beneficiaries even if the beneficiary inquires about a specific code.
- In 1966, CPT® was developed because there was no procedural coding system available to report ambulatory services rendered or services rendered by health care professionals other than physicians.
- In 1983, CPT® was adopted as an integral part of HCPCS and the Medicare program.
- In 1986, CMS (then known as the Health Care Financing Administration [HCFA]) mandated that Medicaid State Agencies use the HCPCS codes.
- HCFA, in 1987, mandated the use of CPT® when reporting outpatient hospital surgical procedures.
- The Secretary published a rule in August 2000 designating CPT® as the standard procedure code set for physicians and other practitioners under the Administrative Simplification provisions of HIPAA. It was chosen because it had been thoroughly tested, enjoyed wide use, was available at a very low cost to users, and could be updated and distributed in a highly efficient manner; no other outpatient/office procedural code set has been so tried and tested.
Problems with Changing from CPT® Coding System
- The problems associated with a change to an entirely new system that would be faced by the health care community—physicians, other health care providers, academic health centers, community health centers, hospitals, ambulatory surgical centers, etc.—would be disastrous to care delivery. The amount of time to prepare for and effectuate such a change would be staggering—at a minimum, five years and, realistically, much longer.
- The cost of such an activity would be equally staggering. The AMA estimated in 1997 that the cost of designating a system other than CPT® as the standard under the Health Insurance Portability and Accountability Act (HIPAA) would be "approaching $1 billion." The cost in time and money is very great and yet would yield nothing that would benefit the health care system as a whole.
- Insurers would have to convert some historical files to permit checking for services that were performed in the past, decide which services to pay for (from perhaps a very broad array of services, including many that are today only theoretically possible), and decide how much to pay for each service.
- Other coding systems do not lend themselves to pricing a service the way CPT® does. CPT® provides clear descriptions of what was removed and how during a surgical procedure, and it includes mechanisms to report whether a service took additional time and clinical judgment or was comparatively routine.
- Compliance during the transition will likely be difficult due to confusion among physicians and hospitals. CPT® utilizes explanatory notes and additional guidance to educate users on how codes are to be used. Any new coding system would have to bear the costs of providing this intensive provider education and support.
- A change would also result in the lack of continuity of data over time. This lack of continuity over time would be true of all systems, including those used for payment of insurance claims to the countless systems that store information for statistical purposes and research purposes. Most historical data will not be translated to the new system. Some cannot be translated to the new system because of differences in the way the coding systems are constructed.
- The problems that would result, if changes as suggested by some were made, would have far-reaching consequences from which an already beleaguered health care system may not ever recover. Furthermore, there is nothing that we see that could be gained by such a change. There is absolutely no cost benefit from such a change, there is no procedural coding system currently in place or even proposed to be developed that can match the confidence and efficacy of the AMA CPT® coding system, and current concerns about compliance would only be greatly compounded under such a proposal.
- It is important to have a coding system that everyone understands and participates in its development and refinement.
- The CPT® coding system with its standard nomenclature is widely accepted and approved, having been tested and proven.
- The CPT® coding system is a system that physicians and providers have learned to use and with which they are comfortable.
CPT® is a registered trademark of the American Medical Association.