Equipment Type – In 2006, GEHC and numerous other clinical societies provided comments to CMS-1321-P regarding the incorrect equipment type and cost used to calculate practice expense for DXA (77080 & 77081). In the final rule CMS-1321-FC published in December 1st (page 137), CMS advised they had revised CPT code 77080 & 77081 to fan beam technology with a cost of $85,000. In reviewing the 2007 input tables, however, the equipment type for both procedures were changed back to pencil beam technology. For the following reasons, we urge CMS to once again revise the PE input data to reflect fan beam technology.
1. The Lewin Group recently conducted a survey representing 8 specialties that provide DXA in an office-based setting with 163 completed surveys, 81% of the machines identified were fan beam with a cost of $85,000.
2. Results of the clinical society survey data conducted in 2006 of 453 physicians showed 93% of all bone densitometry units in use today were fan beam densitometers and 7% were pencil beam.
3. Our records show 90% of all systems sold from 2004-2006 were fan beam densitometers and 10% were pencil beam.
Indirect Percentages – With the implementation of the bottom up methodology, which uses the direct and indirect cost to calculate the PE RVU, it is clear what makes up the direct cost however, the indirect cost is unclear. To date we have been unable to determine how the indirect cost index was determined, how the specialty mix was derived and what specific inputs were used, therefore we request CMS to provide this information so that we may comment appropriately.
Utilization Rate – The utilization rate has a significant impact on direct cost of the PE RVU. Using the same utilization rate for all procedures can lead to significant payment inequities since utilization varies considerably by place of service and type of service (single use device versus multiple use devices).
The Lewin Group survey determined that the utilization rate for DXA in the non-facility setting was 12% and VFA was 6 %. ISCD on behalf of several national clinical societies whose members currently use DXA equipment conducted a study in 2006, which was submitted to CMS that included utilization information. Results of this study showed DXA utilization at a median range of 21% with the majority of systems sold to primary care physicians, rheumatologists, and endocrinologist. Based on CMS’s own 2002 data information 70% of DXA scans were performed in an office-based setting, in which 60% were performed by non-radiologist. Place of service, equipment type (single use versus multiple use), type of service (preventative versus advanced technology), and operating hours should be used in the calculation of utilization. We implore CMS to consider alternative methods for calculating the utilization rate given the significant impact it has on the total PE RVU value for DXA.