2009 RBRVS Update And Impact On Pediatricians

I was privileged to receive a notice from the AAP’s Inner Sanctum about the recently released updates to our friendly RVU system and am sharing it below.  Over the next few days, I will post some pediatric / RVU data relating to the updates that you can’t get anywhere else.

My sincere thanks go to Siouxsie, whose message I have excerpted here.  I will follow up with data, etc.

Please note that I called for pediatricians to write to CMS to discuss their inadequate imms admin payments and I heard from a surprising number who had done so…it looks like your hard work paid off!  Great work.

11/3/08

CMS released the 2009 RBRVS final rule on Friday, October 31st (trick or treat…?). The Federal Register version will be published on November 19th…

I reviewed the final rule and overall, it is filled with treats…

1) Immunization Administration (CPT codes 90465-90474)

Well, our advocacy efforts paid off! Based on the comment letters it received on this issue, CMS has reversed its initial decision not to incorporate the of the RUC-recommendations regarding clinical staff “quality” time. Therefore, the 2009 PE RVUs will include all of the RUC recommendations, including clinical staff time for vaccine registry input, refrigerator/freezer temperature log monitoring/documentation, and refrigerator/freezer alarm monitoring/documentation…

2) New PICU Codes (99475-99476)

CMS agreed with (and published) the RUC recommendations for the new PICU codes for patients aged 2-5 years:

99475 (initial) = 11.25 work RVUs
99476 (subsequent) = 6.75 work RVUs

3) Ocular Photoscreening (99174)

CMS agreed with (and published) the RUC recommendations (for PE only) for the ocular photoscreening code (99174)…

4) ESRD Codes (90951-90959; 90963-90965; 90967-90969)

CMS agreed with (and published) the RUC recommendations for the new ESRD codes…

5) Work GPCI Floor

Per MIPAA, the work GPCI floor of 1.000 will be extended through 12/31/08.

Now for the tricks:

1) Moderate Sedation (99143-99150)

Regardless of the RUC recommendations, CMS continues to leave the moderate sedation (MS) codes as “carrier priced” status and with no published RVUs. During meetings with CMS representatives, we have even offered the option to have CMS publish the RUC-recommended RVUs for the pediatric MS codes, albeit as “N” [noncovered] status. Apparently, CMS representatives were not as receptive to the idea as they might have indicated…We will continue our advocacy efforts, both individually and through the RUC.

2) Medicare 2009 Conversion Factor (CF) & Budget Neutrality Adjuster

The 2009 Medicare CF will be $36.0666 (an omen…?). This was arrived at as follows:

* MIPPA required that the 2009 CF represent a 1.1% increase over the 2008 CF ($38.0870)
* However, CMS has agreed to rescind the budget neutrality factor [utilized in both 2007 and 2008 for “after market” Medicare claims adjudication due to the increases resulting from the 2005 Five-Year Review]
* By rescinding the budget neutrality adjuster, CMS had to find alternative means to achieve Medicare budget neutrality in 2009
* Therefore, CMS has decided to do that via a 6.41% decrease in the 2009 CF
* Additionally, there is a positive 0.08 percent adjustment required to maintain Medicare budget neutrality outside of the Five-Year Review adjustment
* Bottom line: The $36.0666 figure represents a 5.30% decrease from last year (1.1% increase plus a 6.41% decrease plus a 0.08% increase)

I will be back a few times over the next week giving you more details about the impact on pediatricians – I’m going to do a real procedure analysis, a GCPI analysis, etc. Hang tight.

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