In contempo years, a cardinal of codes on the Medicare Physician Fee Schedule acquire accomplished cogent reductions in their acquittal ante due to changes to a distinct absolute convenance amount input. We conducted an assay in May and August 2018, afterward the advertisement of the CY 2019 Proposed Rule, to actuate how abounding added codes are accessible to potentially cogent acquittal reductions because their amount is angry predominantly to a distinct input. Our assay begin 366 codes that acquire the majority of their acquittal amount angry to a distinct absolute convenance amount input.
The Centers for Medicare and Medicaid Casework (CMS) and the American Medical Association Specialty Society About Amount Scale Update Committee (RUC) are reviewing HCPCS codes on an anniversary base to actuate whether the cipher has the adapted about amount assemblage (RVU) on the Medicare Physician Fee Schedule (MPFS). These reviews may be accomplished based on altered triggers, including the following:
Creation of a new cipher or afterlight to an absolute action cipher in a cipher family
Periodic assay of action codes (not beneath frequently than every bristles years) as adapted by Section 1848(c)(2)(B) of the Act
Nomination of a action cipher as allotment of the anniversary assay of potentially misvalued codes, which may abatement into a cardinal of categories, including but not bound to the following:
Codes that acquire accomplished abundant changes in convenance expenses
Codes with aerial intra-service assignment per assemblage of time
Codes with aerial convenance amount RVUs
Codes with aerial amount supplies
In administering its assay of the HCPCS codes, the RUC—on its own or at the appeal of CMS—is accurately gluttonous to actuate the adapted work, convenance amount and abuse RVUs. The convenance amount RVUs, which represent 50 percent or added of the absolute non-facility RVUs in added than 53 percent of the codes, are afflicted in allotment based on the afterward absolute convenance amount inputs.
As allotment of the RUC action and/or the CMS assay process, the units and prices are bent for the aloft types of inputs based on assorted sources. It is important to acquire the specific inputs for an alone cipher and the about accent of anniversary analytic labor, accumulation and accessories ascribe in free the amount for codes of interest. Abundant changes in a distinct ascribe can acquire a affecting aftereffect on the all-embracing acquittal amount for a code. Two contempo examples in above-mentioned rulemaking cycles allegorize the impact.
Home all-embracing normalized arrangement (INR) ecology has two abstruse apparatus that are the key apparatus of the service: demonstration/training (under G0248) and advancing ecology (under G0249). In October 2015, the RUC recommended that these codes be referred to the CPT Editorial Panel for the conception of Class I codes. The Akin II HCPCS “G” codes had been created to apparatus the National Advantage Determination in 2002, but these codes never “graduated” to Akin I CPT codes or underwent RUC assay of their valuations. For CY 2018, the CPT Editorial Panel created the two new codes applicative to the affirmation and training and able estimation of home PT/INR ecology and for the abstruse basic of the advancing capacity of testing accessories and services. While the RUC recommended the abatement of the G codes, CMS absitively to accumulate the absolute three G codes accustomed their use beneath a National Advantage Determination for home PT/INR monitoring.
While allotment to advance the G codes, in the CY 2018 anniversary rulemaking cycle, CMS implemented a change in the assemblage amount for a key absolute convenance amount input—INR assay strips (SJ055). Specifically, CMS repriced the assemblage amount of INR assay strips from $21.86 to $5.66, a abridgement of added than 74 percent. As proposed, this change in a distinct ascribe would acquire alone the acquittal ante for G0248 and G0249 by 44.2 percent and 43.4 percent back absolutely implemented (holding the about-face agency constant). Based on acknowledgment from stakeholders, CMS added the cardinal of units for the INR assay strips from four to six for G0249. With this change, the abridgement of acquittal was mitigated by about 20 percent.
Flow cytometry is appear by two abstracted codes: one for the aboriginal brand (88184) and a abstracted cipher for anniversary added brand (88185). In the CY 2016 anniversary rulemaking cycle, CMS proposed and accomplished cogent changes to the abstruse basic for the two breeze cytometry codes.
Specifically, CMS afflicted the cardinal of units for the lysing abettor (SL089) from 14 mL to 5 mL and 2 mL for 88184 and 88185 respectively. This change, as absolutely implemented and captivation the CY 2016 about-face agency constant, would acquire translated into a 39.3 percent and 69.5 percent bead appropriately for 88184 and 88185. In the two years back the change, a cardinal of stakeholders acquire formed through the RUC action to abate the amount reductions by 29 percent in 88184 and 14 percent in 88185.However, alike with those changes, 88184 accomplished a 28 percent drop, and 88185 (fully implemented and captivation the CY 2018 about-face agency constant) would acquaintance a 59.9 percent drop.
In the CY 2019 MPFS Proposed Rule, CMS proposed cogent changes to prices for a cardinal of absolute convenance amount items. These changes were based on an all-embracing assay of accumulation and accessories appraisement conducted by StrategyGen, a bazaar assay close that CMS affianced beneath its ascendancy accepted by Section 220(a) of the Protecting Access to Medicare Act. To actuate “market” prices for the accumulation and accessories inputs beneath review, the StrategyGen aggregation active abundant approaches, including acreage surveys, accumulated databases, bell-ringer resources, bazaar scans and bazaar analysis. Based on its analysis, StrategyGen recommended changes to about 1,400 inputs as approved in the table below.
In the Proposed Rule, CMS proposed to acquire all the changes, acquainted that while some inputs accomplished changes in their prices, the all-embracing changes were annual neutral. To annual for cogent changes in the proposed prices, CMS proposed to phase-in the changes to amount inputs (if finalized) over a four-year period.
Given these two contempo experiences, as able-bodied as the proposed new amount inputs based on the StrategyGen analysis, McDermott Consulting conducted a abundant assay of the absolute convenance amount database that CMS appear with the CY 2019 MPFS Proposed Rule. The assay focused on the non-facility ambience and articular potentially accessible codes whose convenance amount RVUs (and appropriately agnate acquittal rates) adequate in ample allotment on a distinct input.
To analyze potentially accessible codes, the afterward antecedent code-level belief were set:
Non-facility PE RVU > 50 percent of absolute non-facility RVU
Volume for the cipher > 1,000 based on CY 2016 appliance abstracts crosswalked to 2018 codes
Total amount of the ascribe > $24.99
Then, the assay focused on inputs at the cipher akin aural anniversary of the three categories: labor, accumulation and equipment. For anniversary category, the afterward two added belief were established:
Cost for the distinct ascribe (at the cipher level) > 60 percent of absolute amount in that class for that code
Category (g., equipment, accumulation or labor) > 60 percent of absolute inputs for that code
The assay articular added than 360 codes that are potentially accessible based on the belief accustomed above. Specifically, 43.2 percent of the codes acquire the majority of their RVU angry to a distinct accessories input, with 31.1 percent and 25.7 percent of codes accepting the majority of their RVU angry to a distinct activity or accumulation input, respectively.
In an assay of the cipher ancestors level, the 158 codes articular as accessible due to a distinct accessories ascribe are for 11 altered accessories items. This may not be surprising, as the majority are radiology codes afflicted by one of six items.
For the codes afflicted by a distinct activity input, the majority of the codes are either orthopedic procedures (20000 series) or anesthetic casework and procedures (90000 series).
The three cipher alternation with the accomplished cardinal of codes afflicted by a distinct accumulation ascribe are cardiovascular (33010–37999), anesthetic (90000 series) and urology (50000–53899).
It is important for stakeholders to become added abreast about the potentially accessible codes; to acquire the abeyant appulse of changes to the price, units or time for the key convenance amount inputs; and to accede strategies to abode these issues as appropriate.
 Based on codes in Addendum B of the CY 2018 MPFS Final aphorism area the absolute non-facility RVU is greater than zero.
 G0248 (Demonstration, above-mentioned to admission of home INR monitoring, for accommodating with either automated affection valve(s), abiding atrial fibrillation or venous thromboembolism who meets Medicare advantage criteria, beneath the administration of a physician, includes: contiguous affirmation of use and affliction of the INR monitor, accepting at atomic one claret sample, accouterment of instructions for advertisement home INR assay results, and affidavit of accommodating adeptness to accomplish testing and address results) and G0249 (Provision of assay abstracts and accessories for home INR ecology of accommodating with either automated affection valve(s), abiding atrial fibrillation or venous thromboembolism who meets Medicare advantage criteria; includes accouterment of abstracts for use in the home and advertisement of assay after-effects to physician; testing not occurring added frequently than already a week; testing materials, announcement units of account accommodate four tests).
 93792 (Patient/caregiver training for admission of home INR ecology beneath the administration of a physician or added able bloom affliction professional, face-to-face, including use and affliction of the INR monitor, accepting claret sample, instructions for advertisement home INR assay results, and affidavit of patient’s/caregiver’s adeptness to accomplish testing and address results).
 93793 (Anticoagulant administration for a accommodating demography warfarin, charge accommodate assay and estimation of a new home, appointment or lab INR assay result, accommodating instructions, dosage acclimation (as needed) and scheduling of added test(s), back performed).
 Assuming no added changes to the codes, these changes will be absolutely implemented by CY 2020.
 88184 (Flow cytometry, corpuscle surface, cytoplasmic or nuclear marker, abstruse basic only; aboriginal marker) and 88185 (Flow cytometry, corpuscle surface, cytoplasmic or nuclear marker, abstruse basic only; anniversary added brand (List alone in accession to cipher for aboriginal marker)).
 In CY 2018, CMS accomplished an access in the cardinal of units of antibodies per assay from 1.0 to 1.6.
 Changes for 88185—based on the phase-in policy—are currently to be absolutely implemented in CY 2022.
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