PA

We understand in the HOPPS final rules that HCPCS procedure code 77338 is billed per IMRT plan which is consistent per the AMA, ACR and ASTRO guidelines. This one CPT code contains multiple devices which in the past was charged using CPT code 77334 billed in multiple units and represented substantial payment to the providers from CMS. CMS stated the following in the HOPPS final rule: “We recognize that it is peculiar that the estimated cost for CPT code 77334, which represents the cost of a single device, would be greater than the estimated cost for CPT code 77338, which represents the cost of all devices in a single IMRT plan of treatment, but our estimated costs are based on the amounts of the charges established by hospitals for the service and the hospitals’ CCRs, which are calculated from their Medicare cost reports”. We would implore CMS to give hospitals more time to allow changes in their charge masters, cost reports and systems as currently hospitals are trying to comply with massive changes mandated by Congress and CMS. In the past CMS was more forgiving and understood that hospitals are slow and need time to update their systems. Considering the volume of changes currently undergoing our healthcare system we find it reasonable to give hospitals one more year to effect the changes necessary to update their systems for CPT code 77338. Regards, Tammi M. Holden RT (R)(T) Radiation Oncology Manager Warren General Hospital Cancer Care Center