How the 2017 MPFS Proposed Rules will Impact Radiation Oncology Specialty

The Centers for Medicare & Medicaid Services (CMS) recently published the 2017 Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System. In the proposed rule for 2017, CMS indicated they found a 34 percent decrease in total time to provide service for CPT® code 77332. This possibly means an overall decrease in reimbursement for all treatment devices, negatively impacting the radiation oncology specialty paid through the Medicare Physicians Fee Schedule (MPFS). According to CMS, the 34 percent reduction in total time is not reflected in the recommended RVUs, thus CMS believes that the recommended RVUs overstate the work involved.

The agency is proposing to value the radiation treatment device codes based on a crosswalk with the value of CPT code 93287 Peri-procedural device evaluation (in person). The use of this crosswalk is proposed because CPT code 93287 has identical intraservice time, similar total time, and a similar level of intensity. The Agency further supports this valuation proposal with the inclusion of CPT code 97760Orthotic(s) management and training. Both have a work RVU of 0.45. CMS proposes establishing a work RVU of 0.45 for CPT Code 77332 and retaining the incremental increase for CPT codes 77333 and 77334 reflecting the increase in work value.

CMS will accept comments on the proposed rule until September 6, 2016, and will respond to comments in a final rule. 

When submitting your input, kindly to refer to the specific file code for both the Hospital Outpatient Prospective Payment System (HOPPS) and the MPFS.  Here are instructions for submission:

  • Comments to CMS regarding the HOPPS proposed rule must refer to file code CMS-1656-P.
  • You must submit your comments no later than 5:00 p.m. ET on September 6, 2016.
  • To comment, go to http://www.regulations.gov and follow the instructions under the “submit a comment” tab.
  • Comments to CMS regarding the MPFS proposed rule must refer to file code CMS-1654-P.
  • You must submit your comments no later than 5:00 p.m. ET on September 6, 2016.
  • To comment, go to http://www.regulations.gov and follow the instructions under the “submit a comment” tab.

Radiation oncology coding is often complicated with many distinctions, and applying coding guidance in a consistent manner is critical for all radiation oncologists. AudioEducator will be conducting an expert session on Radiation Oncology: Coding and Documentation. Don’t miss out on that!

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