2013 Medicare Fee Schedule Final Rule Impact on Nephrology ...

Angioplasty Code Reductions
With regard to the angioplasty codes (CPT codes 35475—arterial angioplasty, and
35476—venous angioplasty), the total RVUs for these services were unilaterally reduced
by CMS by approximately 28% and 15%, respectively, from the 2012 values for these
codes.
The reductions for these services came on the heels of review of the services by the
AMA’s Relative Value Update Committee (RUC) in April 2012. As part of the RUC
review process, RPA, the American Society of Diagnostic and Interventional Nephrology
(ASDIN), and allied groups surveyed these codes and presented a collaborative proposal
for valuing the services to the RUC. While the RUC review did result in a slight
reduction of the work values for the codes from previous levels, it was relatively minimal
and the practice expense values for these services (which represents the majority of the
overall value for the services) was preserved. Thus, while the RVUs for the services
were reduced, the vast majority of the total value of the services was preserved, and in
light of the fact that CMS has traditionally accepted 80-90% of RUC recommendations,
RPA and ASDIN believed that the review of the angioplasty codes had been a success
overall.
However, upon review of the final fee schedule rule released by CMS on November 1 it
is clear that CMS did not accept the RUC recommendations. CMS agreed with the
RUC’s approach of selecting a similar service as a starting point for RVU development,
removing overlapping work inputs, and arriving at a recommended RVU for the service.
Unfortunately, CMS selected for the starting points services with substantially lower
work RVUs. As a result, while the RUC recommended 6.60 work RVUs for 35475,
CMS assigned a work RVU of 5.75 to the service. Similarly, in contrast to the RUC
recommendation of 5.50 for 35476, CMS assigned a work RVU of 4.71 to the service.
CMS does note in the rule that these RVU levels are being assigned to the services on an
interim final basis, and RPA will submit comments to the Agency that will point out the
counterproductive impact these reductions may have on fistula creation for kidney
disease patients. However, the advocacy effort to convince CMS to reconsider and
upwardly revise the RVU levels for these services will be quite challenging.
E-Prescribing Changes/Meaningful Use (MU) Hardship Exemptions
The final rule outlined several changes to the e-prescribing program, as noted below:
• The definition of group practice for the eRx Incentive Program is now tied to the
definition of group practice under PQRS. Since CMS is changing the definition of
group practice in PQRS to allow groups of 2-24 eligible professionals (EPs) to
participate in PQRS as a group practice, accordingly, group practices of 2-24
eligible professionals will be able to participate in the eRx Incentive Program as a
group practice in <strong>2013</strong> (that is, for the <strong>2013</strong> incentive and 2014 payment
adjustment).
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