CMS-1385-P Proposed Revisions to payment policies under the physician fee schedule and other Part B payment policies for CY 2008

�� Practice Expense Inputs – CPT 77080
�� Work RVU – CPT 77080
�� Deficit Reduction Act

Comment: Practice Expense Inputs: CPT 77080 – Axial Bone Density Studies

We question the accuracy of the PE RVU formula after several attempts by various sources to include two CMS representatives to duplicate the .81 PE RVU for CPT 77080-Axial BMD, DXA as outlined in the CMS-1385-P PFS proposed rule it could not be duplicated. We contacted Rick Ensor who sent a detail worksheet with the calculation for determining the total PE RVU value. This worksheet showed the value of .85. ISCD received a similar worksheet from a different source with CMS that contained a few different line items within the calculation that showed a total value of .86. It was explained to us that there are rounding differences that would cause the variance. This would account only for a 1-point difference either way not a 5-point difference. When you take both worksheets and compare the direct and indirect cost, there were differences. After entering the same direct cost the variance is .15. It is important to note, that neither worksheet received from CMS matched the value listed in the proposed rule.

CMS has a responsibility to ensure the formula’s used to calculate the physician fee schedule is accurate and reproducible. We believe there is a significant flaw in the formula, therefore we request CMS to re-evaluate the formula.

We request CMS to revise the practice expense inputs for axial bone density studies to reflect differences in the factors: (1) type of equipment assigned to CPT 77080 & 77081, (2) the utilization rate assumption for these procedures; and (3) factors affecting the indirect cost assumptions. Discussion of each of these issues follows.

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