DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

CMS-1503-FC 528
we determine whether we agree with the recommended work RVUs for a service (that is,
we agree the valuation is accurate), or, if we disagree, we determine an alternative value
that better reflects our estimate of the physician work for the service. Because of the
timing of the CPT Editorial Panel decisions, AMA RUC recommendations, and our
rulemaking cycle, we publish these work RVUs in the PFS final rule with comment
period as interim final values, subject to public comment. Similarly, we assess the AMA
RUC's recommendations for direct PE inputs and malpractice crosswalks, and establish
PE and malpractice interim final values, which are also subject to comment. We note
that, with respect to interim final PE RVUs, the main aspect of our valuation that is open
for public comment for a new, revised, or potentially misvalued code is the direct PE
inputs and not the other elements of the PE valuation methodology, such as the indirect
cost allocation methodology, that also contribute to establishing the PE RVUs for a code.
The public comment period on the PFS final rule with comment period remains open for
60 days after the rule is issued.
If we receive public comments on the interim final work RVUs for a specific code
indicating that refinement of the interim final work value is warranted based on sufficient
information from the commenters concerning the clinical aspects of the physician work
associated with the service (57 FR 55917), we refer the service to a refinement panel, as
discussed in further detail in sections III.I. and V.B.1. of this final rule with comment
period.
In the interval between closure of the comment period and the subsequent year's
PFS final rule with comment period, we consider all of the public comments on the
interim final work, PE, and malpractice RVUs for the new, revised, and potentially