Davidson, Loren -- CA

Document ID: CMS-2011-0131-1051
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: December 07 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: 80f7ce1a
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 that the RVUs associated with the new codes CPT 62369 & 62370 do not represent the complexity or the time required for the refill & reprogramming service. Users of the baclofen pump are frequently exceedingly medically complex and appropriate management requires greater assessment than just merely refilling the medication reservoir. It may be useful to include detail about the level of skill and training required to refill and program a pump as CMS may not fully understand the service.