DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

CMS-1503-FC 569
which is a value between the CY 2010 values for CPT code 11040 (0.50 work RVUs)
and CPT code 97597 (0.58 work RVUs), which we have accepted on an interim final
basis in this final rule with comment period for CY 2011. However, the work RVUs for
this CPT code were further subject to a work budget neutrality adjustment, as discussed
in section V.C.1.b.(iii) of this final rule with comment period.
For CPT code 97598, the HCPAC recommended 0.40 work RVUs, the survey
25th percentile. We disagree with the HCPAC-recommended value for this service and,
given the similarity of code descriptors between the 11000 series and the 97000 series
CPT codes, we believe a more appropriate value would be 0.25 RVUs, the survey low
value, as it is more consistent with the work RVU value associated with new add-on CPT
code 11045, discussed above. We also believe the post-service time for CPT code 97598
should be reduced to 0 minutes to coincide with the CPT codes in the 11000 series, which
have 0 or 1 minute of post-service time. Therefore, we are assigning an alternative value
of 0.25 work RVUs to CPT code 97598 and reducing the post-service time to 0 minutes
on an interim final basis for CY 2011. However, the work RVUs for this CPT code were
subject to a work budget neutrality adjustment, as discussed in section V.C.1.b.(iii) of this
final rule with comment period.
(B) Arthrodesis Including Discectomy (CPT code 22551)
As a result of CPT code 22554 (Arthrodesis, anterior interbody, including disc
space preparation, discectomy, osteophytectomy and decompression of spinal cord and/or
nerve roots; cervical, below C2) being reviewed by the AMA RUC because of its
identification by the Five-Year Review Identification Workgroup "Codes Reported
Together" potentially misvalued codes screen in February 2008, CPT code 22551