Frandrup, Christopher -- WY

Document ID: CMS-2011-0131-1049
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: November 30 2011, at 12:00 AM Eastern Standard Time
Date Posted: January 24 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: November 28 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: January 3 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80f76aa8
View Document:

This is comment on Rule

Medicare Programs: Payment Policies Under the Physician Fee Schedule, Five-Year Review of Work Relative Value Units, Clinical Laboratory Fee Schedule: Signature on Requisition, and Other Revisions to Part B for CY 2012

View Comment

I disagree with your ruling on CPT code 62370. The comparison used to make the reduction in RVU was based on programming of a device and does not reflect the amount of work and RISK that is involved with a Intrathecal Pump Device. The mortality rate for pump refills is substantial (~2%) according to some studies. Again, the reduction in RVU's is not justified.