Medicare Program; Five-Year Review of Work Relative Value Units Under the Physician Fee Schedule

Federal RegisterJun 8, 2001

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DEPARTMENT OF HEALTH AND HUMAN SERVICES

Health Care Financing Administration

[HCFA-1170-PN]

RIN 0938-AK56

Medicare Program; Five-Year Review of Work Relative Value Units Under the Physician Fee Schedule

AGENCY:

Health Care Financing Administration (HCFA), HHS.

ACTION:

Proposed notice.

SUMMARY:

This proposed notice discusses changes to work relative value units (RVUs) affecting payment for physicians' services. Section 1848(c)(2)(B)(i) of the Social Security Act requires that we review RVUs no less often than every 5 years. This is the second review of work RVUs since we implemented the physician fee schedule on January 1, 1992. These work RVUs are proposed to be effective for services furnished beginning January 1, 2002.

DATES:

To be assured of consideration, we must receive comments at the appropriate address, as provided below, no later than 5 p.m. on August 7, 2001.

ADDRESSES:

Mail written comments (1 original and 3 copies) to the following address only: Health Care Financing Administration, Department of Health and Human Services, Attention: HCFA-1170-PN, P.O. Box 8013, Baltimore, MD 21244-8013.

Please allow sufficient time for mailed comments to be timely received in the event of delivery delays. If you prefer, you may deliver your written comments by courier (1 original and 3 copies) to one of the following addresses:

Room 445-G, Hubert H. Humphrey Building, 200 Independence Avenue, SW., Washington, DC 20201,

or

Room C5-14-03, 7500 Security Boulevard, Baltimore, MD 21244-8013

Comments mailed to the above addresses may be delayed and received too late to be considered.

Because of staff and resource limitations, we cannot accept comments by facsimile (FAX) transmission. In commenting, please refer to file code HCFA-1170-PN. Comments received timely will be available for public inspection as they are received, generally beginning approximately 3 weeks after publication of a document at the headquarters of the Health Care Financing Administration, 7500 Security Boulevard, Baltimore, Maryland, on Monday through Friday of each week from 8:30 a.m. to 5 p.m. Please call (410) 786-7197 to make an appointment to view the public comments.

FOR FURTHER INFORMATION CONTACT:

Jim Menas, (410) 786-4507.

Rick Ensor, (410) 786-5617.

Diane Milstead, (410) 786-3355.

Marc Hartstein (Regulatory Impact Analysis), (410) 786-4539.

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To assist readers in referencing sections contained in the preamble, we are providing the following table of contents:

Table of Contents

I. Background

A. Legislative History

B. Published Changes to the Physician Fee Schedule

C. Current Proposed Notice

D. The 5-Year Review Process

II. Discussion of Comments and Decisions

A. Review of Comments

B. Discussion of Comments by Clinical Area

1. Vascular Surgery

2. General Surgery/Colon and Rectal Surgery

3. Thoracic Surgery

4. Orthopedic Surgery

5. Ophthalmology

6. Urology

7. Obstetrics/Gynecology

a. Specialty Comments

b. Other Concerns

8. Gastroenterology

9. Pulmonary Medicine/Critical Care

10. Cardiology

11. Pediatrics

12. Pediatric Surgery

13. Radiology

14. Plastic Surgery

C. Other Comments

1. Anesthesia Services

2. Spine Injection Procedures

3. Biofeedback

4. Surgical Management of Burn Wounds

5. Transplantation

6. Arthroscopy Services

7. Wheelchair Management

8. Psychological Testing

9. Podiatric Services

D. Other Issues

1. Critical Care Services in a Global Period

2. Codes Referred to CPT

3. Budget Neutrality

4. Calculation of Practice Expense and Malpractice Relative Value Units

5. Nature and Format of Comments on Work Relative Value Units

III. Collection of Information Requirements

IV. Response to Comments

V. Regulatory Impact Analysis

Because of the many organizations and terms to which we refer by acronym in this proposed notice, we are listing these acronyms and their corresponding terms in alphabetical order below:

AANA Arthroscopy Association of North America

AAO American Academy of Opthalmology

AAP American Academy of Pediatrics

ABA American Burn Association

ACG American College of Gastroenterology

ACOG American College of Obstetrics and Gynecology

ACR American College of Radiology

ACS American College of Surgeons

AGA American Gastrointestinal Association

AMA American Medical Association

APMA American Podiatric Medical Association

APSA American Pediatric Surgical Association

APTA American Physical Therapy Association

ASA American Society of Anesthesiologists

ASCRS American Society of Colon and Rectal Surgeons

ASGE American Society for Gastrointestinal Endoscopy

ASPS American Society of Plastic Surgery

ASTS American Society for Transplant Surgeons

AUA American Urological Association

BBA Balanced Budget Act

CPT Current procedural terminology

CY Calendar year

ERCP Endoscopic retrograde cholangio-pancreatography

FDA Food and Drug Administration

FR

Federal Register

GAF Geographic adjustment factor

GCPI Geographic practice cost index

GPO Government Printing Office

HCFA Health Care Financing Administration

HCPAC Health Care Professionals Advisory Committee

HCPCS HCFA Common Procedure Coding System

HHS Health and Human Services

IWPUT Intra-service work per unit of time

MEI Medicare economic index

MQSA Mammography Quality Standards Act of 1992

MSA Metropolitan statistical area

PE Practice expense

PEAC Practice Expense Advisory Committee

RFA Regulatory Flexibility Act

RIA Regulatory impact analysis

RUC [AMA's Specialty Society] Relative [Value] Update Committee

RVU Relative value unit

STS Society of Thoracic Surgeons

SVS Society for Vascular Surgery

I. Background

A. Legislative History

Since January 1, 1992, Medicare has paid for physician services under section 1848 of the Social Security Act (the Act), “Payment for Physicians” Services.” This section contains three major elements, (1) a fee schedule for the payment of physicians' services; (2) a sustainable growth rate for the rates of increase in Medicare expenditures for physicians' services; and (3) limits on the amounts that nonparticipating physicians can charge beneficiaries. The Act requires that payments under the fee schedule be based on national uniform relative value units (RVUs) based on the resources used in furnishing a service. Section 1848(c) of the Act requires that national RVUs be established for physician work, practice expense, and malpractice expense.

Section 1848(c)(2)(B)(ii)(II) of the Act provides that adjustments in RVUs may not cause total physician fee schedule payments to differ by more than $20 million from what they would have been had the adjustments not been made. If this tolerance is exceeded, we must make adjustments to the conversion factors (CFs) to preserve budget neutrality.

B. Published Changes to the Physician Fee Schedule

In the July 2000 proposed rule (65 FR 44177), we listed all of the final rules published through November 1999, relating to updates to the RVUs and revisions to the payment policies under the physician fee schedule. In the November 2000 final rule (65 FR 65376), we finalized the calendar year (CY) 2000 interim physician work RVUs and issued new interim work RVUs for new and revised codes for CY 2001. The final rule also discussed the activities underway with respect to the second 5-year refinement of work RVUs.

C. Current Proposed Notice

This proposed notice discusses changes to work RVUs affecting payment for physicians' services. Section 1848(c)(2)(B)(i) of the Act requires that we review RVUs no less often than every 5 years. We implemented the physician fee schedule effective for services furnished beginning January 1, 1992: the first 5-year review of work was initiated in December 1994 and was effective for services furnished beginning January 1, 1997. The revisions proposed in this notice are subject to a 60-day public comment period. We will review public comments, make adjustments as appropriate, and include revised values in our physician fee schedule final rule, to be published by November 1, 2001, effective for services furnished beginning January 1, 2002.

D. The 5-Year Review Process

We initiated the second 5-year review by soliciting public comments on potentially misvalued work RVUs for all services in the 2000 physician fee schedule in our November 2, 1999 final rule (64 FR 59427). To allow sufficient time for recommendations, we provided a 120-day comment period. We included a discussion of the activities underway with respect to the second 5-year refinement of work RVUs in the July 17, 2000 proposed rule (65 FR 44201).

We received comments from approximately 30 specialty groups, organizations, and individuals involving over 900 CPT and HCPCS codes. We also received comments on the proposed process for the 5-year review. As we indicated in the November 2, 1999 final rule and in the July 17, 2000 proposed rule, we shared these comments with the AMA Specialty Society Relative Value Update Committee (RUC). The RUC was formed in November 1991 and grew out of a series of discussions between the AMA and major national medical specialty societies. The work of the RUC is supported by the RUC Advisory Committee, which is made up of representatives of 100 specialty societies in the AMA's House of Delegates.

The RUC currently makes recommendations to us on RVUs for new and revised CPT codes (hereafter referred to as codes). This process was used during the first 5-year review, and we believe that it was beneficial. We indicated that we believe the perspective of the RUC is helpful because of its experience in recommending RVUs for the codes that have been added to, or revised by, the CPT panel since we implemented the physician fee schedule in 1992. By virtue of its multispecialty membership and consultation with specialty societies, the RUC involves the medical community in formulating its recommendations. For codes used only by non-physician practitioners, the Health Care Professionals Advisory Committee (HCPAC), a companion to the RUC, has made recommendations to us.

As we stated in the first 5-year review, we retain the responsibility for analyzing the comments and recommendations, developing the proposed rule, evaluating comments on the proposed rule, and deciding whether to revise RVUs.

After we sent the RUC the comments we received on potentially misvalued services, the RUC identified specialty societies interested in making presentations concerning those misvalued services. In making presentations to the RUC, specialty societies compiled data using a standard survey instrument whereby respondents compared the surveyed service with similar “reference” services that have established, agreed upon work values. Respondents were asked to estimate the work for the survey code, the time to perform pre-, intra-, and postservice activities, and the technical skill, risk, and judgement involved with performing the service. Postservice activities were broken down into hospital and office visits and were assigned an appropriate evaluation and management code by the respondent. Each specialty society selected the physician sample that was surveyed. A minimum of 30 responses was required by the RUC for the survey to be considered valid.

For this 5-year review, the RUC permitted a specialty society to use a “minisurvey” for some codes if the number of codes a specialty was reviewing was extremely high. These minisurveys required less information from the respondent but were similar in design.

Some specialty societies used a “building-block” approach to validate the survey results for surgical services. In constructing the building blocks, a service is divided into “pre-”, “intra-”, and “post-” service components. The preservice component consists of all services furnished before the physician makes the skin incision (for example, preoperative evaluation and scrubbing)

the intraservice component consists of the “skin-to-skin” time, and the postservice component includes immediate postsurgery services and subsequent hospital and office visits. Each component (or building block) is then assigned work RVUs. Preservice and intraservice work RVUs are based on time and intensity, and postservice work is based on the specified evaluation and management service for each postoperative visit. These three values are then summed to compute “building-block” work RVUs.

The results of the surveys were reviewed and organized by the specialty society and then presented to the RUC. Based on the survey results and a discussion, the RUC developed a recommendation. The RUC used six workgroups to evaluate the codes. Each workgroup evaluated a series of related codes and submitted its report to the full RUC. The RUC then evaluated those reports and sent recommendations to us. Both the workgroups and the RUC evaluated the relative work (time and intensity) for each service compared to other services on the fee schedule.

We received recommendations on work RVUs from the RUC for all of the codes we forwarded, with the exception of the anesthesia codes and conscious sedation codes.

II. Discussion of Comments and Decisions

A. Review of Comments

During the comment period for our November 2, 1999 final rule, we received approximately 35 public comments on approximately 900 codes. After review by our medical staff, we forwarded all of the comments we received concerning misvalued services to the RUC. The RUC submitted work RVU recommendations for all of the codes we forwarded with the exception of the anesthesia codes and conscious sedation codes. The RUC used six workgroups to evaluate the codes. Each workgroup evaluated a series of related codes and submitted its report to the full RUC. The RUC then evaluated those reports and sent its recommendations to us. Both the workgroups and the RUC evaluated the relative work (time and intensity) for each service compared to other services on the fee schedule.

As discussed below, we further analyzed all of the RUC recommendations; we evaluated both the recommended work RVUs and the rationale for the recommendations. If we had concerns about the application of a particular methodology, we verified that the recommended work RVUs were appropriate by using alternative methodologies.

Table 1, Five-Year Review of Work Relative Value Units, lists the codes reviewed during the 5-year review. This table includes the following information:

•

CPT/HCPCS Code.

This is the CPT or alphanumeric HCPCS code for a service.

•

Modifier.

A modifier-26 is shown if the work RVUs represent the professional component of the service.

•

Description.

This is an abbreviated version of the narrative description of the code.

•

2000 Work RVUs.

The work RVUs that appeared in the November 2, 1999 final rule are shown for each reviewed code.

•

Requested Work RVUs.

This column identifies the work RVUs requested by the commenting specialty or individual commenter. If we received more than one comment on a code, the code is listed more than once with the recommended RVUs. If the commenters did not recommend specific RVUs, we indicate this by “N/A”. A “WD” (withdrawal) indicates the commenter withdrew the request for review of a code and chose not to pursue review of the code under the 5-year review.

•

RUC Recommendation.

This column identifies the work RVUs recommended by the RUC. “CPT” indicates that that the RUC referred this code to the AMA CPT Editorial Panel for review and clarification and recommended maintaining the current work RVUs. An “(e)” indicates the commenting specialty withdrew the proposal; therefore, the RUC recommends maintaining the current work RVUs.

•

HCPAC Recommendation.

This column identifies the work RVUs recommended by the HCPAC. An “(a)” in this column indicates there was no HCPAC recommendation.

•

HCFA Decision.

This column indicates whether we agreed with the RUC recommendation (“agree”); we are proposing work RVUs higher than the RUC recommendation (“increase”); or we are proposing work RVUs that are less than the RUC recommendation (“decrease”). Codes for which we did not accept the RUC recommendation are discussed in greater detail following Table 1. An “(a)” in this column indicates that in the absence of a RUC recommendation we are proposing to maintain the present work RVUs. A “(b)” in this column indicates that these services were reviewed as part of the July 2000 Multispecialty Refinement Panels for new and/or revised services. (Meetings of Multispecialty Refinement Panels are conducted as needed to allow specialty representatives the opportunity to discuss the comments they submitted on our decisions on new or revised services published in the final rule. The goal of multispecialty refinement panels is to consider the interests of those who commented on the work RVUs against the redistributive effects that would occur in other specialties. Following each discussion of a specific service, panel members were instructed to individually rate the service under discussion. We then used a statistical analysis of these ratings to create final work RVUs for the services under discussion.) A “(d)” indicates there was no HCPAC recommendation. We propose maintaining current work RVUs.

•

Proposed work RVUs:

This column contains the 2002 proposed work RVUs.

The following is a categorization of our proposals as related to the RUC recommended work RVUs from the 5-year review of work RVUs. The RUC supplied us with recommendations on 857 services. We accepted RUC's recommended work RVUs for 792 of the services reviewed and disagreed with RUC's recommended work RVUs for 65 of the services reviewed. This is an acceptance percentage of 92 percent. Of the 65 services for which we did not accept the RUC's recommended work RVUs we increased the work RVUs for 37 services, decreased the work RVUs for 22 services, and rejected the RUC recommendation of an increase for 6 services that had already been reviewed at the Multispecialty Refinement Panel for CY 2000.

Additionally, the HCPAC reviewed a total of 12 services as part of the 5-year review. For 5 of the services reviewed, the HCPAC did not offer a recommendation. Of the remaining 7 services reviewed by the HCPAC, we have accepted the HCPAC recommendations.

——————————

1

All CPT codes and descriptors copyright 2000 American Medical Association

Table 1.—Five-Year Review of Work Relative Value Units

CPT/HCPCS

code

1

Mod

Descriptor

2000

work RVU

Requested

work RVU

RUC

REC

HCPAC

REC

HCFA

decision

Proposed

work RVU

11055

Trim skin lesion

0.27

0.43

(a)

(a)

0.27

11056

Trim skin lesion, 2 to 4

0.39

0.61

(a)

(a)

0.39

11057

Trim skin lesions, over 4

0.50

0.79

(a)

(a)

0.50

11100

Biopsy of skin lesion

0.81

WD

(e)

(a)

0.81

11402

Removal of skin lesion

1.61

2.20

1.61

agree

1.61

11642

Removal of skin lesion

2.93

3.05

2.93

agree

2.93

11642

Removal of skin lesion

2.93

3.87

2.93

agree

2.93

11719

Trim nail(s)

0.11

0.17

(a)

(a)

0.11

11730

Removal of nail plate

1.13

WD

(e)

(a)

1.13

12001

Repair superficial wound(s)

1.70

N/A

CPT

CPT

1.70

12002

Repair superficial wound(s)

1.86

N/A

CPT

CPT

1.86

12011

Repair superficial wound(s)

1.76

2.37

1.76

agree

1.76

13101

Repair of wound or lesion

3.92

5.43

3.92

agree

3.92

13131

Repair of wound or lesion

3.79

4.79

3.79

agree

3.79

13132

Repair of wound or lesion

5.95

6.95

5.95

agree

5.95

15000

Skin graft

4.00

5.95

CPT

CPT

4.00

15001

Skin graft add-on

1.00

2.50

CPT

CPT

1.00

15100

Skin split graft

9.05

9.05

CPT

CPT

9.05

15101

Skin split graft add-on

1.72

1.72

CPT

CPT

1.72

15120

Skin split graft

9.83

9.83

CPT

CPT

9.83

15121

Skin split graft add-on

2.67

2.67

CPT

CPT

2.67

15350

Skin homograft

4.00

4.00

CPT

CPT

4.00

15351

Skin homograft add-on

1.00

1.00

CPT

CPT

1.00

15400

Skin heterograft

4.00

4.00

CPT

CPT

4.00

15401

Skin heterograft add-on

1.00

1.00

CPT

CPT

1.00

17000

Destroy benign/premal lesion

0.60

WD

(e)

(a)

0.60

17003

Destroy lesions, 2-14

0.15

WD

(e)

(a)

0.15

17004

Destroy lesions, 15 or more

2.79

WD

(e)

(a)

2.79

19000

Drainage of breast lesion

0.84

1.27

0.84

agree

0.84

19100

Biopsy of breast

1.27

3.88

1.27

agree

1.27

19125

Excision, breast lesion

6.06

9.00

6.06

agree

6.06

19160

Removal of breast tissue

5.99

8.38

5.99

agree

5.99

19162

Remove breast tissue, nodes

13.53

15.68

13.53

agree

13.53

19240

Removal of breast

16.00

18.87

16.00

agree

16.00

20205

Deep muscle biopsy

2.35

3.42

CPT

CPT

2.35

20245

Bone biopsy, excisional

3.95

7.97

8.50

decrease

7.78

20600

Drain/inject, joint/bursa

0.66

WD

(e)

(a)

0.66

20605

Drain/inject, joint/bursa

0.68

WD

(e)

(a)

0.68

21740

Reconstruction of sternum

16.50

21.00

CPT

CPT

16.50

21800

Treatment of rib fracture

0.96

1.77

0.96

agree

0.96

23076

Removal of shoulder lesion

7.63

13.40

CPT

CPT

7.63

23472

Reconstruct shoulder joint

16.92

21.27

21.10

agree

21.10

23485

Revision of collar bone

13.43

18.73

13.43

agree

13.43

23585

Treat scapula fracture

8.96

11.46

8.96

agree

8.96

23615

Treat humerus fracture

9.35

15.85

9.35

agree

9.35

23630

Treat humerus fracture

7.35

12.45

7.35

agree

7.35

23680

Treat dislocation/fracture

10.06

13.10

10.06

agree

10.06

24076

Remove arm/elbow lesion

6.30

10.20

CPT

CPT

6.30

24435

Repair humerus with graft

13.17

20.36

13.17

agree

13.17

24545

Treat humerus fracture

10.46

12.26

10.46

agree

10.46

25076

Removal of forearm lesion

4.92

12.96

CPT

CPT

4.92

26562

Repair of web finger

9.68

12.56

15.00

agree

15.00

27048

Remove hip/pelvis lesion

6.25

13.01

CPT

CPT

6.25

27075

Extensive hip surgery

17.23

28.52

35.00

agree

35.00

27077

Extensive hip surgery

23.13

30.00

40.00

agree

40.00

27216

Treat pelvic ring fracture

15.19

25.00

15.19

agree

15.19

27217

Treat pelvic ring fracture

14.11

17.11

14.11

agree

14.11

27218

Treat pelvic ring fracture

20.15

22.15

20.15

agree

20.15

27226

Treat hip wall fracture

14.91

19.91

14.91

agree

14.91

27236

Treat thigh fracture

15.60

17.60

15.60

agree

15.60

27280

Fusion of sacroiliac joint

13.39

21.00

13.39

agree

13.39

27282

Fusion of pubic bones

11.34

21.66

11.34

agree

11.34

27284

Fusion of hip joint

16.76

20.12

23.45

agree

23.45

27328

Removal of thigh lesion

5.57

8.70

CPT

CPT

5.57

27472

Repair/graft of thigh

17.72

23.62

17.72

agree

17.72

27513

Treatment of thigh fracture

17.92

20.92

17.92

agree

17.92

27536

Treat knee fracture

15.65

19.00

15.65

agree

15.65

27590

Amputate leg at thigh

12.03

15.52

12.03

agree

12.03

27619

Remove lower leg lesion

8.40

10.02

CPT

CPT

8.40

27724

Repair/graft of tibia

14.99

19.34

18.20

agree

18.20

27822

Treatment of ankle fracture

9.20

10.68

11.00

agree

11.00

27823

Treatment of ankle fracture

11.80

13.27

13.00

agree

13.00

27828

Treat lower leg fracture

16.23

19.00

16.23

agree

16.23

28299

Correction of bunion

8.88

11.90

9.18

agree

9.18

28322

Repair of metatarsals

8.34

13.26

8.34

agree

8.34

28420

Treat/graft heel fracture

16.64

23.52

16.64

agree

16.64

28445

Treat ankle fracture

9.33

15.97

15.62

agree

15.62

28705

Fusion of foot bones

15.21

20.46

18.80

agree

18.80

29450

Application of leg cast

1.02

3.00

2.08

agree

2.08

29450

Application of leg cast

1.02

N/A

2.08

agree

2.08

29881

Knee arthroscopy/surgery

7.76

WD

(e)

(a)

7.76

29883

Knee arthroscopy/surgery

9.46

12.00

11.05

agree

11.05

29889

Knee arthroscopy/surgery

15.13

16.68

16.00

agree

16.00

29889

Knee arthroscopy/surgery

15.13

18.47

16.00

agree

16.00

31600

Incision of windpipe

3.62

6.42

7.18

agree

7.18

31622

Dx bronchoscope/wash

2.78

4.17

2.78

agree

2.78

31622

Dx bronchoscope/wash

2.78

N/A

2.78

agree

2.78

31625

Bronchoscopy with biopsy

3.37

N/A

3.37

agree

3.37

31645

Bronchoscopy, clear airways

3.16

N/A

3.16

agree

3.16

32000

Drainage of chest

1.54

2.88

1.54

agree

1.54

32000

Drainage of chest

1.54

N/A

1.54

agree

1.54

32005

Treat lung lining chemically

2.19

N/A

2.19

agree

2.19

32020

Insertion of chest tube

3.98

N/A

3.98

agree

3.98

32035

Exploration of chest

8.67

N/A

8.67

agree

8.67

32095

Biopsy through chest wall

8.36

N/A

8.36

agree

8.36

32100

Exploration/biopsy of chest

11.84

N/A

15.24

agree

15.24

32110

Explore/repair chest

13.62

N/A

23.00

agree

23.00

32220

Release of lung

19.27

N/A

24.00

agree

24.00

32225

Partial release of lung

13.96

N/A

13.96

agree

13.96

32320

Free/remove chest lining

20.54

N/A

24.00

agree

24.00

32440

Removal of lung

21.02

35.08

25.00

agree

25.00

32440

Removal of lung

21.02

N/A

25.00

agree

25.00

32480

Partial removal of lung

18.32

27.17

23.75

agree

23.75

32480

Partial removal of lung

18.32

N/A

23.75

agree

23.75

32482

Bilobectomy

19.71

N/A

25.00

agree

25.00

32491

Lung volume reduction

21.25

N/A

21.25

agree

21.25

32500

Partial removal of lung

14.30

N/A

22.00

agree

22.00

32520

Remove lung & revise chest

21.68

N/A

21.68

agree

21.68

32602

Thoracoscopy, diagnostic

5.96

N/A

5.96

agree

5.96

32651

Thoracoscopy, surgical

12.91

N/A

12.91

agree

12.91

32652

Thoracoscopy, surgical

18.66

N/A

18.66

agree

18.66

32655

Thoracoscopy, surgical

13.10

N/A

13.10

agree

13.10

32657

Thoracoscopy, surgical

13.65

N/A

13.65

agree

13.65

33207

Insertion of heart pacemaker

8.04

WD

(e)

(a)

8.04

33234

Removal of pacemaker system

7.82

N/A

7.82

agree

7.82

33235

Removal of pacemaker electrode

9.40

N/A

9.40

agree

9.40

33400

Repair of aortic valve

25.34

N/A

28.50

agree

28.50

33405

Replacement of aortic valve

30.61

N/A

35.00

agree

35.00

33406

Replacement of aortic valve

32.30

N/A

37.50

agree

37.50

33410

Replacement of aortic valve

32.46

N/A

32.46

agree

32.46

33411

Replacement of aortic valve

32.47

N/A

36.25

agree

36.25

33412

Replacement of aortic valve

34.79

N/A

42.00

agree

42.00

33413

Replacement of aortic valve

35.24

N/A

43.50

agree

43.50

33415

Revision, subvalvular tissue

27.15

N/A

27.15

agree

27.15

33425

Repair of mitral valve

27.00

N/A

27.00

agree

27.00

33426

Repair of mitral valve

31.03

N/A

33.00

agree

33.00

33427

Repair of mitral valve

33.72

N/A

40.00

agree

40.00

33430

Replacement of mitral valve

31.43

N/A

33.50

agree

33.50

33468

Revision of tricuspid valve

30.12

N/A

30.12

agree

30.12

33475

Replacement, pulmonary valve

28.41

N/A

33.00

agree

33.00

33506

Repair artery, translocation

26.71

N/A

35.50

agree

35.50

33510

CABG, vein, single

25.12

N/A

29.00

agree

29.00

33511

CABG, vein, two

27.40

N/A

30.00

agree

30.00

33512

CABG, vein, three

29.67

N/A

31.80

agree

31.80

33513

CABG, vein, four

31.95

N/A

32.00

agree

32.00

33514

CABG, vein, five

35.00

N/A

32.75

agree

32.75

33516

Cabg, vein, six or more

37.40

N/A

35.00

agree

35.00

33517

CABG, artery-vein, single

2.57

N/A

2.57

agree

2.57

33518

CABG, artery-vein, two

4.85

N/A

4.85

agree

4.85

33519

CABG, artery-vein, three

7.12

N/A

7.12

agree

7.12

33521

CABG, artery-vein, four

9.40

N/A

9.40

agree

9.40

33522

CABG, artery-vein, five

11.67

N/A

11.67

agree

11.67

33523

Cabg, art-vein, six or more

13.95

N/A

13.95

agree

13.95

33530

Coronary artery, bypass/reop

5.86

N/A

5.86

agree

5.86

33533

CABG, arterial, single

25.83

N/A

30.00

agree

30.00

33534

CABG, arterial, two

28.82

N/A

32.20

agree

32.20

33535

CABG, arterial, three

31.81

N/A

34.50

agree

34.50

33536

Cabg, arterial, four or more

34.79

N/A

37.50

agree

37.50

33611

Repair double ventricle

32.30

N/A

34.00

agree

34.00

33612

Repair double ventricle

33.26

N/A

35.00

agree

35.00

33615

Repair, simple fontan

32.06

N/A

34.00

agree

34.00

33617

Repair, modified fontan

34.03

N/A

37.00

agree

37.00

33619

Repair single ventricle

37.57

N/A

45.00

agree

45.00

33641

Repair heart septum defect

21.39

N/A

21.39

agree

21.39

33660

Repair of heart defects

25.54

N/A

30.00

agree

30.00

33670

Repair of heart chambers

32.73

N/A

35.00

agree

35.00

33681

Repair heart septum defect

27.67

N/A

30.61

agree

30.61

33694

Repair of heart defects

31.73

N/A

34.00

agree

34.00

33697

Repair of heart defects

33.71

N/A

36.00

agree

36.00

33730

Repair heart-vein defect(s)

31.67

N/A

34.25

agree

34.25

33750

Major vessel shunt

21.41

N/A

21.41

agree

21.41

33767

Major vessel shunt

24.50

N/A

24.50

agree

24.50

33770

Repair great vessels defect

33.29

N/A

37.00

agree

37.00

33778

Repair great vessels defect

35.82

N/A

40.00

agree

40.00

33780

Repair great vessels defect

36.94

N/A

41.75

agree

41.75

33786

Repair arterial trunk

34.84

N/A

39.00

agree

39.00

33820

Revise major vessel

16.29

N/A

16.29

agree

16.29

33840

Remove aorta constriction

20.63

N/A

20.63

agree

20.63

33860

Ascending aortic graft

33.96

N/A

38.00

agree

38.00

33861

Ascending aortic graft

34.52

N/A

42.00

agree

42.00

33863

Ascending aortic graft

36.47

N/A

45.00

agree

45.00

33870

Transverse aortic arch graft

40.31

N/A

44.00

agree

44.00

33875

Thoracic aortic graft

33.06

N/A

CPT

CPT

33.06

33877

Thoracoabdominal graft

42.60

N/A

CPT

CPT

42.60

33917

Repair pulmonary artery

24.50

N/A

24.50

agree

24.50

33919

Repair pulmonary atresia

32.67

N/A

40.00

agree

40.00

33945

Transplantation of heart

42.10

N/A

42.10

agree

42.10

34001

Removal of artery clot

12.91

WD

(e)

(a)

12.91

34101

Removal of artery clot

9.97

N/A

10.00

agree

10.00

34111

Removal of arm artery clot

8.07

N/A

10.00

agree

10.00

34151

Removal of artery clot

16.86

27.51

25.00

agree

25.00

34151

Removal of artery clot

16.86

28.00

25.00

agree

25.00

34201

Removal of artery clot

9.13

10.40

10.03

agree

10.03

34201

Removal of artery clot

9.13

10.58

10.03

agree

10.03

34203

Removal of leg artery clot

12.21

14.99

16.50

agree

16.50

34203

Removal of leg artery clot

12.21

16.50

16.50

agree

16.50

34401

Removal of vein clot

12.86

26.63

25.00

agree

25.00

34401

Removal of vein clot

12.86

28.00

25.00

agree

25.00

34421

Removal of vein clot

9.93

15.75

12.00

agree

12.00

34421

Removal of vein clot

9.93

15.94

12.00

agree

12.00

34451

Removal of vein clot

14.44

29.05

27.00

agree

27.00

34451

Removal of vein clot

14.44

30.00

27.00

agree

27.00

34490

Removal of vein clot

7.60

N/A

9.86

agree

9.86

34501

Repair valve, femoral vein

10.93

N/A

16.00

agree

16.00

34510

Transposition of vein valve

13.25

N/A

18.95

agree

18.95

34520

Cross-over vein graft

13.74

N/A

17.95

agree

17.95

34530

Leg vein fusion

17.61

N/A

16.64

agree

16.64

35011

Repair defect of artery

11.65

14.10

18.00

agree

18.00

35011

Repair defect of artery

11.65

18.00

18.00

agree

18.00

35013

Repair artery rupture, arm

17.40

15.38

22.00

agree

22.00

35013

Repair artery rupture, arm

17.40

20.00

22.00

agree

22.00

35045

Repair defect of arm artery

11.26

11.05

17.57

agree

17.57

35045

Repair defect of arm artery

11.26

16.50

17.57

agree

17.57

35081

Repair defect of artery

28.01

33.13

28.01

agree

28.01

35082

Repair artery rupture, aorta

36.35

37.00

38.50

agree

38.50

35082

Repair artery rupture, aorta

36.35

41.80

38.50

agree

38.50

35092

Repair artery rupture, aorta

38.39

50.00

45.00

agree

45.00

35092

Repair artery rupture, aorta

38.39

58.61

45.00

agree

45.00

35103

Repair artery rupture, groin

33.57

41.00

40.50

agree

40.50

35103

Repair artery rupture, groin

33.57

44.12

40.50

agree

40.50

35111

Repair defect of artery

16.43

23.24

25.00

agree

25.00

35111

Repair defect of artery

16.43

28.00

25.00

agree

25.00

35112

Repair artery rupture,spleen

18.69

29.20

30.00

agree

30.00

35112

Repair artery rupture,spleen

18.69

30.00

30.00

agree

30.00

35121

Repair defect of artery

25.99

30.29

30.00

agree

30.00

35121

Repair defect of artery

25.99

32.00

30.00

agree

30.00

35122

Repair artery rupture, belly

33.45

36.83

35.00

agree

35.00

35122

Repair artery rupture, belly

33.45

37.00

35.00

agree

35.00

35131

Repair defect of artery

18.55

23.15

25.00

agree

25.00

35131

Repair defect of artery

18.55

28.00

25.00

agree

25.00

35132

Repair artery rupture, groin

21.95

30.00

30.00

agree

30.00

35132

Repair artery rupture, groin

21.95

30.54

30.00

agree

30.00

35141

Repair defect of artery

14.46

19.38

20.00

agree

20.00

35141

Repair defect of artery

14.46

20.00

20.00

agree

20.00

35142

Repair artery rupture, thigh

15.86

23.36

23.30

agree

23.30

35142

Repair artery rupture, thigh

15.86

25.00

23.30

agree

23.30

35151

Repair defect of artery

17.00

20.26

22.64

agree

22.64

35151

Repair defect of artery

17.00

22.00

22.64

agree

22.64

35152

Repair artery rupture, knee

16.70

24.98

25.62

agree

25.62

35152

Repair artery rupture, knee

16.70

27.50

25.62

agree

25.62

35182

Repair blood vessel lesion

17.74

N/A

30.00

agree

30.00

35184

Repair blood vessel lesion

12.25

N/A

18.00

agree

18.00

35189

Repair blood vessel lesion

18.43

N/A

28.00

agree

28.00

35190

Repair blood vessel lesion

12.75

N/A

12.75

agree

12.75

35201

Repair blood vessel lesion

9.99

12.74

16.14

agree

16.14

35201

Repair blood vessel lesion

9.99

18.35

16.14

agree

16.14

35206

Repair blood vessel lesion

9.25

N/A

13.25

agree

13.25

35221

Repair blood vessel lesion

16.42

26.00

24.39

agree

24.39

35221

Repair blood vessel lesion

16.42

28.95

24.39

agree

24.39

35226

Repair blood vessel lesion

9.06

14.00

14.50

agree

14.50

35226

Repair blood vessel lesion

9.06

15.82

14.50

agree

14.50

35231

Repair blood vessel lesion

12.00

15.64

20.00

agree

20.00

35231

Repair blood vessel lesion

12.00

18.90

20.00

agree

20.00

35236

Repair blood vessel lesion

10.54

12.85

17.11

agree

17.11

35236

Repair blood vessel lesion

10.54

18.00

17.11

agree

17.11

35246

Repair blood vessel lesion

19.84

26.00

26.45

agree

26.45

35246

Repair blood vessel lesion

19.84

N/A

26.45

agree

26.45

35251

Repair blood vessel lesion

17.49

31.00

30.20

agree

30.20

35251

Repair blood vessel lesion

17.49

34.04

30.20

agree

30.20

35256

Repair blood vessel lesion

11.38

N/A

18.36

agree

18.36

35261

Repair blood vessel lesion

11.63

15.51

17.80

agree

17.80

35261

Repair blood vessel lesion

11.63

18.90

17.80

agree

17.80

35266

Repair blood vessel lesion

10.30

15.79

14.91

agree

14.91

35266

Repair blood vessel lesion

10.30

17.00

14.91

agree

14.91

35276

Repair blood vessel lesion

18.75

22.00

24.25

agree

24.25

35276

Repair blood vessel lesion

18.75

N/A

24.25

agree

24.25

35281

Repair blood vessel lesion

16.48

29.00

28.00

agree

28.00

35281

Repair blood vessel lesion

16.48

32.01

28.00

agree

28.00

35286

Repair blood vessel lesion

11.87

N/A

16.16

agree

16.16

35311

Rechanneling of artery

23.85

30.00

27.00

agree

27.00

35311

Rechanneling of artery

23.85

N/A

27.00

agree

27.00

35321

Rechanneling of artery

11.97

16.47

16.00

agree

16.00

35321

Rechanneling of artery

11.97

18.35

16.00

agree

16.00

35331

Rechanneling of artery

23.52

24.81

26.20

agree

26.20

35331

Rechanneling of artery

23.52

28.01

26.20

agree

26.20

35351

Rechanneling of artery

20.11

24.09

23.00

agree

23.00

35351

Rechanneling of artery

20.11

25.50

23.00

agree

23.00

35355

Rechanneling of artery

16.09

20.01

18.50

agree

18.50

35355

Rechanneling of artery

16.09

20.75

18.50

agree

18.50

35361

Rechanneling of artery

23.59

29.08

28.20

agree

28.20

35361

Rechanneling of artery

23.59

30.00

28.20

agree

28.20

35363

Rechanneling of artery

24.66

32.00

30.20

agree

30.20

35363

Rechanneling of artery

24.66

35.67

30.20

agree

30.20

35371

Rechanneling of artery

11.64

12.97

14.72

agree

14.72

35371

Rechanneling of artery

11.64

17.75

14.72

agree

14.72

35372

Rechanneling of artery

13.56

18.04

18.00

agree

18.00

35372

Rechanneling of artery

13.56

19.53

18.00

agree

18.00

35381

Rechanneling of artery

15.81

N/A

CPT

CPT

15.81

35511

Artery bypass graft

16.83

19.75

21.20

agree

21.20

35511

Artery bypass graft

16.83

21.50

21.20

agree

21.20

35518

Artery bypass graft

15.42

18.59

21.20

agree

21.20

35518

Artery bypass graft

15.42

23.00

21.20

agree

21.20

35521

Artery bypass graft

16.17

20.46

22.20

agree

22.20

35521

Artery bypass graft

16.17

25.25

22.20

agree

22.20

35526

Artery bypass graft

20.00

30.00

29.95

agree

29.95

35526

Artery bypass graft

20.00

N/A

29.95

agree

29.95

35531

Artery bypass graft

25.61

33.62

36.20

agree

36.20

35531

Artery bypass graft

25.61

38.00

36.20

agree

36.20

35533

Artery bypass graft

20.52

28.00

28.00

agree

28.00

35533

Artery bypass graft

20.52

29.99

28.00

agree

28.00

35536

Artery bypass graft

23.11

25.33

31.70

agree

31.70

35536

Artery bypass graft

23.11

33.00

31.70

agree

31.70

35541

Artery bypass graft

25.80

N/A

CPT

CPT

25.80

35546

Artery bypass graft

25.54

N/A

CPT

CPT

25.54

35551

Artery bypass graft

26.67

N/A

CPT

CPT

26.67

35556

Artery bypass graft

21.76

24.50

21.76

agree

21.76

35556

Artery bypass graft

21.76

24.50

21.76

agree

21.76

35558

Artery bypass graft

14.04

22.00

21.20

agree

21.20

35558

Artery bypass graft

14.04

22.08

21.20

agree

21.20

35560

Artery bypass graft

23.56

28.19

32.00

agree

32.00

35560

Artery bypass graft

23.56

35.50

32.00

agree

32.00

35563

Artery bypass graft

15.14

24.00

24.20

agree

24.20

35563

Artery bypass graft

15.14

25.00

24.20

agree

24.20

35565

Artery bypass graft

15.14

23.65

23.20

agree

23.20

35565

Artery bypass graft

15.14

24.00

23.20

agree

23.20

35571

Artery bypass graft

18.58

23.65

24.06

agree

24.06

35571

Artery bypass graft

18.58

26.92

24.06

agree

24.06

35582

Vein bypass graft

27.13

N/A

CPT

CPT

27.13

35587

Vein bypass graft

19.05

24.47

24.75

agree

24.75

35587

Vein bypass graft

19.05

27.00

24.75

agree

24.75

35621

Artery bypass graft

14.54

16.53

20.00

agree

20.00

35621

Artery bypass graft

14.54

21.50

20.00

agree

20.00

35623

Bypass graft, not vein

16.62

17.62

24.00

agree

24.00

35623

Bypass graft, not vein

16.62

25.75

24.00

agree

24.00

35626

Artery bypass graft

23.63

27.58

27.75

agree

27.75

35626

Artery bypass graft

23.63

30.00

27.75

agree

27.75

35631

Artery bypass graft

24.60

32.51

34.00

agree

34.00

35631

Artery bypass graft

24.60

36.00

34.00

agree

34.00

35636

Artery bypass graft

22.46

27.32

29.50

agree

29.50

35636

Artery bypass graft

22.46

36.00

29.50

agree

29.50

35641

Artery bypass graft

24.57

N/A

CPT

CPT

24.57

35646

Artery bypass graft

25.81

N/A

CPT

CPT

25.81

35650

Artery bypass graft

14.36

15.74

19.00

agree

19.00

35650

Artery bypass graft

14.36

19.80

19.00

agree

19.00

35654

Artery bypass graft

18.61

23.54

25.00

agree

25.00

35654

Artery bypass graft

18.61

26.00

25.00

agree

25.00

35661

Artery bypass graft

13.18

17.89

19.00

agree

19.00

35661

Artery bypass graft

13.18

19.53

19.00

agree

19.00

35663

Artery bypass graft

14.17

20.90

22.00

agree

22.00

35663

Artery bypass graft

14.17

23.00

22.00

agree

22.00

35665

Artery bypass graft

15.40

19.84

21.00

agree

21.00

35665

Artery bypass graft

15.40

22.00

21.00

agree

21.00

35666

Artery bypass graft

19.19

20.00

22.19

agree

22.19

35666

Artery bypass graft

19.19

22.00

22.19

agree

22.19

35671

Artery bypass graft

14.80

17.80

19.33

agree

19.33

35671

Artery bypass graft

14.80

24.00

19.33

agree

19.33

35701

Exploration, carotid artery

5.55

9.38

8.50

agree

8.50

35701

Exploration, carotid artery

5.55

15.00

8.50

agree

8.50

35721

Exploration, femoral artery

5.28

N/A

7.18

agree

7.18

35741

Exploration popliteal artery

5.37

N/A

8.00

agree

8.00

35840

Explore abdominal vessels

9.77

N/A

CPT

CPT

9.77

35860

Explore limb vessels

5.55

N/A

CPT

CPT

5.55

35905

Excision, graft, thorax

18.19

32.00

31.25

agree

31.25

35905

Excision, graft, thorax

18.19

N/A

31.25

agree

31.25

35907

Excision, graft, abdomen

19.24

37.33

35.00

agree

35.00

35907

Excision, graft, abdomen

19.24

40.00

35.00

agree

35.00

36400

Drawing blood

0.18

N/A

0.38

decrease

0.18

36405

Drawing blood

0.18

N/A

0.32

decrease

0.18

36406

Drawing blood

0.18

N/A

CPT

CPT

0.18

36489

Insertion of catheter, vein

1.22

2.75

2.50

agree

2.50

36489

Insertion of catheter, vein

1.22

3.41

2.50

agree

2.50

36520

Plasma and/or cell exchange

1.74

N/A

CPT

CPT

1.74

36533

Insertion of access device

5.32

5.28

CPT

CPT

5.32

36534

Revision of access device

2.80

5.15

CPT

CPT

2.80

36535

Removal of access device

2.27

3.89

CPT

CPT

2.27

36600

Withdrawal of arterial blood

0.32

WD

(e)

(a)

0.32

36620

Insertion catheter, artery

1.15

2.25

CPT

CPT

1.15

36625

Insertion catheter, artery

2.11

2.65

2.11

agree

2.11

36822

Insertion of cannula(s)

5.42

19.00

5.42

agree

5.42

37565

Ligation of neck vein

4.44

9.01

10.88

agree

10.88

37565

Ligation of neck vein

4.44

14.50

10.88

agree

10.88

37600

Ligation of neck artery

4.57

9.19

11.25

agree

11.25

37600

Ligation of neck artery

4.57

14.00

11.25

agree

11.25

37605

Ligation of neck artery

6.19

11.85

13.11

agree

13.11

37605

Ligation of neck artery

6.19

17.50

13.11

agree

13.11

37609

Temporal artery procedure

2.30

3.38

3.00

agree

3.00

37609

Temporal artery procedure

2.30

N/A

3.00

agree

3.00

37615

Ligation of neck artery

5.73

12.31

CPT

CPT

5.73

37615

Ligation of neck artery

5.73

18.00

CPT

CPT

5.73

37617

Ligation of abdomen artery

15.95

N/A

22.06

agree

22.06

37618

Ligation of extremity artery

4.84

N/A

CPT

CPT

4.84

37650

Revision of major vein

5.13

N/A

7.80

agree

7.80

37660

Revision of major vein

10.61

N/A

21.00

agree

21.00

37700

Revise leg vein

3.73

N/A

CPT

CPT

3.73

37720

Removal of leg vein

5.66

10.71

CPT

CPT

5.66

37730

Removal of leg veins

7.33

N/A

CPT

CPT

7.33

37735

Removal of leg veins/lesion

10.53

N/A

CPT

CPT

10.53

37760

Revision of leg veins

10.47

N/A

CPT

CPT

10.47

37785

Revision secondary varicosity

3.84

N/A

CPT

CPT

3.84

38100

Removal of spleen, total

13.01

14.70

14.50

agree

14.50

38100

Removal of spleen, total

13.01

16.21

14.50

agree

14.50

38101

Removal of spleen, partial

13.74

14.79

15.31

agree

15.31

38115

Repair of ruptured spleen

14.19

15.55

15.82

agree

15.82

38300

Drainage, lymph node lesion

1.53

1.01

1.99

agree

1.99

38305

Drainage, lymph node lesion

4.61

6.59

6.00

agree

6.00

38308

Incision of lymph channels

4.95

7.35

6.45

agree

6.45

38500

Biopsy/removal, lymph nodes

2.88

3.29

3.75

agree

3.75

38500

Biopsy/removal, lymph nodes

2.88

4.58

3.75

agree

3.75

38510

Biopsy/removal, lymph nodes

4.14

6.28

6.43

agree

6.43

38520

Biopsy/removal, lymph nodes

5.12

6.93

6.67

agree

6.67

38525

Biopsy/removal, lymph nodes

4.66

5.30

6.07

agree

6.07

38530

Biopsy/removal, lymph nodes

6.13

9.58

7.98

agree

7.98

38571

Laparoscopy, lymphadenectomy

12.38

19.84

12.38

agree

12.38

38572

Laparoscopy, lymphadenectomy

14.32

23.17

16.59

agree

16.59

38740

Remove armpit lymph nodes

6.77

10.68

8.42

increase

10.02

38745

Remove armpit lymph nodes

8.84

12.78

11.00

increase

13.00

38746

Remove thoracic lymph nodes

4.39

N/A

4.89

agree

4.89

38760

Remove groin lymph nodes

8.74

11.35

10.88

increase

12.94

38765

Remove groin lymph nodes

16.06

18.77

19.98

agree

19.98

38780

Remove abdomen lymph nodes

16.59

N/A

16.59

agree

16.59

39010

Exploration of chest

11.79

N/A

11.79

agree

11.79

39220

Removal chest lesion

17.42

N/A

17.42

agree

17.42

39400

Visualization of chest

5.61

N/A

5.61

agree

5.61

39503

Repair of diaphragm hernia

34.85

122.75

95.00

decrease

34.85

42205

Reconstruct cleft palate

9.59

12.00

13.29

agree

13.29

43107

Removal of esophagus

28.79

N/A

40.00

agree

40.00

43112

Removal of esophagus

31.22

N/A

43.50

agree

43.50

43117

Partial removal of esophagus

30.02

N/A

40.00

agree

40.00

43122

Parital removal of esophagus

29.11

N/A

40.00

agree

40.00

43215

Esophagus endoscopy

2.60

4.91

CPT

CPT

2.60

43217

Esophagus endoscopy

2.90

3.63

2.90

agree

2.90

43219

Esophagus endoscopy

2.80

3.50

3.18

decrease

2.80

43228

Esoph endoscopy, ablation

3.77

4.72

3.77

agree

3.77

43239

Upper GI endoscopy, biopsy

2.69

2.96

2.87

decrease

2.69

43239

Upper GI endoscopy, biopsy

2.69

3.79

2.87

decrease

2.69

43244

Upper GI endoscopy/ligation

4.59

5.05

5.05

decrease

4.59

43246

Place gastrostomy tube

4.33

4.76

4.33

agree

4.33

43246

Place gastrostomy tube

4.33

5.04

4.33

agree

4.33

43247

Operative upper GI endoscopy

3.39

4.51

3.59

decrease

3.39

43249

Esoph endoscopy, dilation

2.90

5.01

3.35

decrease

2.90

43251

Operative upper GI endoscopy

3.70

4.44

3.70

agree

3.70

43255

Operative upper GI endoscopy

4.40

5.40

4.82

decrease

4.40

43258

Operative upper GI endoscopy

4.55

5.01

4.55

agree

4.55

43259

Endoscopic ultrasound exam

4.89

N/A

8.59

decrease

4.89

43263

Endo cholangiopancreatograph

6.19

7.12

7.29

decrease

6.19

43265

Endo cholangiopancreatograph

8.90

N/A

10.02

decrease

8.90

43269

Endo cholangiopancreatograph

6.04

7.50

8.21

decrease

6.04

43305

Repair esophagus and fistula

17.15

WD

(e)

(a)

17.15

43310

Repair of esophagus

25.39

50.50

CPT

CPT

25.39

43312

Repair esophagus and fistula

28.42

56.75

CPT

CPT

28.42

43320

Fuse esophagus & stomach

16.07

26.45

19.93

agree

19.93

43324

Revise esophagus & stomach

16.58

17.75

20.57

agree

20.57

43325

Revise esophagus & stomach

16.17

21.65

20.06

agree

20.06

43326

Revise esophagus & stomach

15.91

20.53

19.74

agree

19.74

43330

Repair of esophagus

15.94

15.44

19.77

agree

19.77

43331

Repair of esophagus

16.23

17.60

20.13

agree

20.13

43340

Fuse esophagus & intestine

15.81

26.72

19.61

agree

19.61

43341

Fuse esophagus & intestine

16.81

29.07

20.85

agree

20.85

43350

Surgical opening, esophagus

12.72

32.97

15.78

agree

15.78

43351

Surgical opening, esophagus

14.79

31.92

18.35

agree

18.35

43352

Surgical opening, esophagus

12.30

25.47

15.26

agree

15.26

43360

Gastrointestinal repair

28.78

61.17

35.70

agree

35.70

43361

Gastrointestinal repair

32.65

65.83

40.50

agree

40.50

43400

Ligate esophagus veins

17.09

29.96

21.20

agree

21.20

43401

Esophagus surgery for veins

17.81

34.94

22.09

agree

22.09

43405

Ligate/staple esophagus

16.13

36.67

20.01

agree

20.01

43410

Repair esophagus wound

10.86

13.65

13.47

agree

13.47

43415

Repair esophagus wound

17.06

30.45

25.00

agree

25.00

43420

Repair esophagus opening

11.57

14.10

14.35

agree

14.35

43425

Repair esophagus opening

16.95

26.93

21.03

agree

21.03

43500

Surgical opening of stomach

8.44

11.81

11.05

agree

11.05

43501

Surgical repair of stomach

15.31

20.44

20.04

agree

20.04

43502

Surgical repair of stomach

17.67

21.20

23.13

agree

23.13

43510

Surgical opening of stomach

9.99

18.81

13.08

agree

13.08

43520

Incision of pyloric muscle

7.63

8.88

9.99

agree

9.99

43605

Biopsy of stomach

9.15

10.41

11.98

agree

11.98

43610

Excision of stomach lesion

11.15

17.37

14.60

agree

14.60

43611

Excision of stomach lesion

13.63

23.82

17.84

agree

17.84

43620

Removal of stomach

22.54

33.61

30.04

agree

30.04

43621

Removal of stomach

23.06

35.55

30.73

agree

30.73

43622

Removal of stomach

24.41

35.56

32.53

agree

32.53

43631

Removal of stomach, partial

19.66

23.28

22.59

agree

22.59

43632

Removal of stomach, partial

19.66

25.92

22.59

agree

22.59

43633

Removal of stomach, partial

20.10

27.68

23.10

agree

23.10

43634

Removal of stomach, partial

21.86

34.19

25.12

agree

25.12

43638

Removal of stomach, partial

21.76

29.96

29.00

agree

29.00

43638

Removal of stomach, partial

21.76

39.80

29.00

agree

29.00

43639

Removal of stomach, partial

22.25

39.80

29.65

agree

29.65

43640

Vagotomy & pylorus repair

14.81

17.32

17.02

agree

17.02

43641

Vagotomy & pylorus repair

15.03

21.34

17.27

agree

17.27

43651

Laparoscopy, vagus nerve

10.15

15.17

10.15

agree

10.15

43652

Laparoscopy, vagus nerve

12.15

19.21

12.15

agree

12.15

43800

Reconstruction of pylorus

10.46

11.86

13.69

agree

13.69

43810

Fusion of stomach and bowel

11.19

13.81

14.65

agree

14.65

43820

Fusion of stomach and bowel

11.74

15.78

15.37

agree

15.37

43825

Fusion of stomach and bowel

14.68

18.16

19.22

agree

19.22

43830

Place gastrostomy tube

7.28

7.28

9.53

agree

9.53

43832

Place gastrostomy tube

11.92

11.92

15.60

agree

15.60

43840

Repair of stomach lesion

11.89

11.89

15.56

agree

15.56

43842

Gastroplasty for obesity

14.71

17.14

18.47

agree

18.47

43843

Gastroplasty for obesity

14.85

20.62

18.65

agree

18.65

43846

Gastric bypass for obesity

19.15

23.43

24.05

agree

24.05

43847

Gastric bypass for obesity

21.44

29.95

26.92

agree

26.92

43848

Revision gastroplasty

23.41

27.07

29.39

agree

29.39

43850

Revise stomach-bowel fusion

19.69

23.27

24.72

agree

24.72

43855

Revise stomach-bowel fusion

20.83

24.15

26.16

agree

26.16

43860

Revise stomach-bowel fusion

19.91

26.08

25.00

agree

25.00

43865

Revise stomach-bowel fusion

21.12

27.30

26.52

agree

26.52

43870

Repair stomach opening

7.40

9.65

9.69

agree

9.69

43880

Repair stomach-bowel fistula

19.63

23.60

24.65

agree

24.65

44005

Freeing of bowel adhesion

13.84

15.43

16.23

agree

16.23

44010

Incision of small bowel

10.68

15.90

12.52

agree

12.52

44020

Exploration of small bowel

11.93

15.04

13.99

agree

13.99

44021

Decompress small bowel

12.01

15.18

14.08

agree

14.08

44025

Incision of large bowel

12.18

14.08

14.28

agree

14.28

44050

Reduce bowel obstruction

11.40

13.75

14.03

agree

14.03

44050

Reduce bowel obstruction

11.40

14.58

14.03

agree

14.03

44055

Correct malrotation of bowel

13.14

22.00

22.00

agree

22.00

44110

Excision of bowel lesion(s)

10.07

14.39

11.81

agree

11.81

44111

Excision of bowel lesion(s)

12.19

16.32

14.29

agree

14.29

44120

Removal of small intestine

14.50

15.82

17.00

agree

17.00

44125

Removal of small intestine

14.96

17.54

17.54

agree

17.54

44130

Bowel to bowel fusion

12.36

17.87

14.49

agree

14.49

44130

Bowel to bowel fusion

12.36

N/A

14.49

agree

14.49

44140

Partial removal of colon

18.35

20.94

18.35

increase

21.00

44140

Partial removal of colon

18.35

24.58

18.35

increase

21.00

44143

Partial removal of colon

20.17

30.36

20.17

increase

22.99

44144

Partial removal of colon

18.89

29.46

18.89

increase

21.53

44144

Partial removal of colon

18.89

N/A

18.89

increase

21.53

44145

Partial removal of colon

23.18

27.91

23.18

increase

26.42

44146

Partial removal of colon

24.16

30.97

24.16

increase

27.54

44147

Partial removal of colon

18.17

N/A

18.17

increase

20.71

44150

Removal of colon

21.01

27.41

21.01

increase

23.95

44151

Removal of colon/ileostomy

20.04

32.89

20.04

increase

26.88

44151

Removal of colon/ileostomy

20.04

N/A

20.04

increase

26.88

44152

Removal of colon/ileostomy

24.41

33.61

24.41

increase

27.83

44153

Removal of colon/ileostomy

26.83

33.11

26.83

increase

30.59

44155

Removal of colon/ileostomy

24.44

33.61

24.44

increase

27.86

44156

Removal of colon/ileostomy

23.01

36.27

23.01

increase

30.79

44156

Removal of colon/ileostomy

23.01

N/A

23.01

increase

30.79

44160

Removal of colon

15.88

17.45

18.62

agree

18.62

44200

Laparoscopy, enterolysis

14.44

16.11

14.44

agree

14.44

44300

Open bowel to skin

8.88

13.09

12.11

agree

12.11

44310

Ileostomy/jejunostomy

11.70

18.14

15.95

agree

15.95

44312

Revision of ileostomy

5.88

6.79

8.02

agree

8.02

44314

Revision of ileostomy

11.04

14.45

15.05

agree

15.05

44316

Devise bowel pouch

15.47

26.57

21.09

agree

21.09

44320

Colostomy

12.94

18.84

17.64

agree

17.64

44340

Revision of colostomy

5.66

6.79

7.72

agree

7.72

44345

Revision of colostomy

11.32

14.45

15.43

agree

15.43

44346

Revision of colostomy

12.46

17.19

16.99

agree

16.99

44388

Colon endoscopy

2.82

3.10

3.70

decrease

2.82

44389

Colonoscopy with biopsy

3.13

3.44

4.26

decrease

3.13

44390

Colonoscopy for foreign body

3.83

4.21

4.81

decrease

3.83

44391

Colonoscopy for bleeding

4.32

4.75

5.18

decrease

4.32

44392

Colonoscopy and polypectomy

3.82

4.20

4.81

decrease

3.82

44393

Colonoscopy, lesion removal

4.84

5.32

5.00

decrease

4.84

44394

Colonoscopy w/snare

4.43

4.87

4.43

agree

4.43

44394

Colonoscopy w/snare

4.43

N/A

4.43

agree

4.43

44602

Suture, small intestine

10.61

15.26

11.91

increase

16.03

44603

Suture, small intestine

14.00

19.50

15.72

increase

18.66

44604

Suture, large intestine

14.28

16.59

16.03

agree

16.03

44605

Repair of bowel lesion

15.37

25.03

17.25

increase

19.53

44615

Intestinal stricturoplasty

14.19

18.97

15.93

agree

15.93

44620

Repair bowel opening

10.87

14.99

12.20

agree

12.20

44625

Repair bowel opening

13.41

16.79

15.05

agree

15.05

44626

Repair bowel opening

22.59

24.43

25.36

agree

25.36

44640

Repair bowel-skin fistula

14.83

22.29

16.65

increase

21.65

44650

Repair bowel fistula

15.25

22.29

17.12

increase

22.27

44660

Repair bowel-bladder fistula

14.63

24.70

16.42

increase

21.36

44661

Repair bowel-bladder fistula

16.99

25.63

19.07

increase

24.81

44680

Surgical revision, intestine

13.72

21.32

15.40

agree

15.40

44700

Suspend bowel w/prosthesis

14.35

19.35

16.11

agree

16.11

44800

Excision of bowel pouch

11.23

10.85

11.23

agree

11.23

44820

Excision of mesentery lesion

10.31

11.23

12.09

agree

12.09

44850

Repair of mesentery

9.57

12.00

10.74

agree

10.74

44900

Drain app abscess, open

8.82

11.79

10.14

agree

10.14

44950

Appendectomy

8.70

8.37

10.00

agree

10.00

44960

Appendectomy

10.74

13.67

12.34

agree

12.34

44970

Laparoscopy, appendectomy

8.70

10.26

8.70

agree

8.70

45000

Drainage of pelvic abscess

4.52

10.29

3.88

increase

4.52

45020

Drainage of rectal abscess

4.72

7.71

4.05

increase

4.72

45100

Biopsy of rectum

3.68

4.34

3.16

increase

3.68

45108

Removal of anorectal lesion

4.76

5.25

4.09

increase

4.76

45110

Removal of rectum

23.80

29.53

28.00

agree

28.00

45111

Partial removal of rectum

16.48

N/A

16.48

agree

16.48

45112

Removal of rectum

25.96

32.46

30.54

agree

30.54

45113

Partial proctectomy

25.99

33.11

30.58

agree

30.58

45114

Partial removal of rectum

23.22

29.46

27.32

agree

27.32

45116

Partial removal of rectum

20.89

21.98

24.58

agree

24.58

45119

Remove rectum w/reservoir

26.21

31.60

30.84

agree

30.84

45120

Removal of rectum

24.60

31.09

24.60

agree

24.60

45121

Removal of rectum and colon

27.04

32.14

27.04

agree

27.04

45123

Partial proctectomy

14.20

22.51

16.71

agree

16.71

45126

Pelvic exenteration

38.39

47.99

45.16

agree

45.16

45130

Excision of rectal prolapse

13.97

14.26

16.44

agree

16.44

45135

Excision of rectal prolapse

16.39

30.14

19.28

agree

19.28

45160

Excision of rectal lesion

13.02

19.86

15.32

agree

15.32

45170

Excision of rectal lesion

9.77

12.81

11.49

agree

11.49

45190

Destruction, rectal tumor

8.28

9.09

9.74

agree

9.74

45305

Proctosigmoidoscopy & biopsy

1.01

1.22

1.01

agree

1.01

45309

Proctosigmoidoscopy

2.01

2.45

2.01

agree

2.01

45330

Diagnostic sigmoidoscopy

0.96

1.39

0.96

agree

0.96

45337

Sigmoidoscopy & decompress

2.36

N/A

2.36

agree

2.36

45339

Sigmoidoscopy

3.14

N/A

3.14

agree

3.14

45378

Diagnostic colonoscopy

3.70

4.66

3.70

agree

3.70

45380

Colonoscopy and biopsy

4.01

5.01

4.44

decrease

4.01

45383

Lesion removal colonoscopy

5.87

7.34

5.87

agree

5.87

45384

Colonoscopy

4.70

5.88

4.70

agree

4.70

45385

Lesion removal colonoscopy

5.31

6.64

5.31

agree

5.31

45505

Repair of rectum

6.02

7.57

7.58

agree

7.58

45540

Correct rectal prolapse

12.92

17.79

16.27

agree

16.27

45541

Correct rectal prolapse

10.64

13.23

13.40

agree

13.40

45550

Repair rectum/remove sigmoid

18.26

27.91

23.00

agree

23.00

45560

Repair of rectocele

8.40

7.70

10.58

agree

10.58

45562

Exploration/repair of rectum

12.21

12.09

15.38

agree

15.38

45563

Exploration/repair of rectum

18.63

21.50

23.47

agree

23.47

45800

Repair rect/bladder fistula

14.11

14.36

17.77

agree

17.77

45805

Repair fistula w/colostomy

16.50

20.94

20.78

agree

20.78

45820

Repair rectourethral fistula

14.67

13.81

18.48

agree

18.48

45825

Repair fistula w/colostomy

16.87

20.38

21.25

agree

21.25

45900

Reduction of rectal prolapse

1.83

3.27

2.61

agree

2.61

45905

Dilation of anal sphincter

1.61

3.15

2.30

agree

2.30

45910

Dilation of rectal narrowing

1.96

3.23

2.80

agree

2.80

45910

Dilation of rectal narrowing

1.96

N/A

2.80

agree

2.80

45915

Remove rectal obstruction

2.20

3.58

3.14

agree

3.14

46040

Incision of rectal abscess

4.96

5.53

4.26

increase

4.96

46045

Incision of rectal abscess

4.32

5.38

3.71

increase

4.32

46060

Incision of rectal abscess

5.69

8.55

4.89

increase

5.69

46083

Incise external hemorrhoid

1.40

1.52

1.40

agree

1.40

46083

Incise external hemorrhoid

1.40

2.34

1.40

agree

1.40

46221

Ligation of hemorrhoid(s)

1.43

1.94

2.04

agree

2.04

46230

Removal of anal tabs

2.57

1.94

2.57

agree

2.57

46250

Hemorrhoidectomy

4.53

4.13

3.89

agree

3.89

46255

Hemorrhoidectomy

5.36

4.98

4.60

agree

4.60

46257

Remove hemorrhoids & fissure

6.28

5.43

5.40

agree

5.40

46258

Remove hemorrhoids & fistula

6.67

5.86

5.73

agree

5.73

46258

Remove hemorrhoids & fistula

6.67

N/A

5.73

agree

5.73

46260

Hemorrhoidectomy

7.42

6.18

6.37

agree

6.37

46261

Remove hemorrhoids & fissure

8.24

7.11

7.08

agree

7.08

46262

Remove hemorrhoids & fistula

8.73

7.11

7.50

agree

7.50

46270

Removal of anal fistula

3.72

4.28

3.20

increase

3.72

46275

Removal of anal fistula

4.56

5.18

3.92

increase

4.56

46280

Removal of anal fistula

5.98

5.95

5.14

increase

5.98

46288

Repair anal fistula

7.13

8.08

6.13

increase

7.13

46320

Removal of hemorrhoid clot

1.61

1.52

1.61

agree

1.61

46320

Removal of hemorrhoid clot

1.61

2.63

1.61

agree

1.61

46700

Repair of anal stricture

7.25

10.22

9.13

agree

9.13

46705

Repair of anal stricture

7.17

6.90

6.90

agree

6.90

46715

Repair of anovaginal fistula

7.46

7.20

7.20

agree

7.20

46716

Repair of anovaginal fistula

12.15

15.15

15.07

agree

15.07

46730

Construction of absent anus

21.57

25.50

26.75

agree

26.75

46735

Construction of absent anus

25.94

36.00

32.17

agree

32.17

46740

Construction of absent anus

23.11

35.00

30.00

agree

30.00

46742

Repair of imperforated anus

29.67

38.00

35.80

agree

35.80

46744

Repair of cloacal anomaly

33.21

52.00

52.63

agree

52.63

46746

Repair of cloacal anomaly

36.74

53.50

58.22

agree

58.22

46748

Repair of cloacal anomaly

40.52

55.00

64.21

agree

64.21

46750

Repair of anal sphincter

8.14

10.99

10.25

agree

10.25

46753

Reconstruction of anus

6.58

5.45

8.29

agree

8.29

46754

Removal of suture from anus

1.54

2.93

2.20

agree

2.20

46760

Repair of anal sphincter

11.46

21.77

14.43

agree

14.43

46761

Repair of anal sphincter

10.99

12.15

13.84

agree

13.84

46762

Implant artificial sphincter

10.09

15.01

12.71

agree

12.71

46900

Destruction, anal lesion(s)

1.91

1.32

1.91

agree

1.91

46910

Destruction, anal lesion(s)

1.86

1.72

1.86

agree

1.86

46916

Cryosurgery, anal lesion(s)

1.86

1.72

1.86

agree

1.86

46917

Laser surgery, anal lesions

1.86

3.32

1.86

agree

1.86

46922

Excision of anal lesion(s)

1.86

3.12

1.86

agree

1.86

46924

Destruction, anal lesion(s)

2.76

3.93

2.76

agree

2.76

46924

Destruction, anal lesion(s)

2.76

4.24

2.76

agree

2.76

46934

Destruction of hemorrhoids

4.08

4.63

3.51

agree

3.51

46935

Destruction of hemorrhoids

2.43

4.17

2.43

agree

2.43

46936

Destruction of hemorrhoids

4.30

5.12

3.69

agree

3.69

46940

Treatment of anal fissure

2.32

1.71

2.32

agree

2.32

46942

Treatment of anal fissure

2.04

1.71

2.04

agree

2.04

46945

Ligation of hemorrhoids

2.14

2.37

1.84

agree

1.84

46946

Ligation of hemorrhoids

3.00

2.57

2.58

agree

2.58

47010

Open drainage, liver lesion

10.28

16.25

16.01

agree

16.01

47015

Inject/aspirate liver cyst

9.70

19.15

15.11

agree

15.11

47100

Wedge biopsy of liver

7.49

9.24

11.67

agree

11.67

47120

Partial removal of liver

22.79

39.57

35.50

agree

35.50

47122

Extensive removal of liver

35.39

53.02

55.13

agree

55.13

47125

Partial removal of liver

31.58

44.50

49.19

agree

49.19

47130

Partial removal of liver

34.25

46.45

53.35

agree

53.35

47134

Partial removal, donor liver

39.15

49.00

CPT

CPT

39.15

47300

Surgery for liver lesion

9.68

12.45

15.08

agree

15.08

47350

Repair liver wound

12.56

19.16

19.56

agree

19.56

47360

Repair liver wound

17.28

28.64

26.92

agree

26.92

47361

Repair liver wound

30.25

40.14

47.12

agree

47.12

47362

Repair liver wound

11.88

24.94

18.51

agree

18.51

47400

Incision of liver duct

20.86

35.12

32.49

agree

32.49

47420

Incision of bile duct

16.72

27.63

19.88

agree

19.88

47425

Incision of bile duct

16.68

32.49

19.83

agree

19.83

47460

Incise bile duct sphincter

15.17

25.74

18.04

agree

18.04

47480

Incision of gallbladder

9.10

15.26

10.82

agree

10.82

47562

Laparoscopic cholecystectomy

11.09

9.59

11.09

agree

11.09

47563

Laparoscopic cholecystectomy

11.94

12.40

11.94

agree

11.94

47564

Laparo cholecystectomy/explr

14.23

17.67

14.23

agree

14.23

47570

Laparo cholecystoenterostomy

12.58

18.62

12.58

agree

12.58

47600

Removal of gallbladder

11.42

11.67

13.58

agree

13.58

47605

Removal of gallbladder

12.36

13.26

14.69

agree

14.69

47610

Removal of gallbladder

15.83

17.97

18.82

agree

18.82

47612

Removal of gallbladder

15.80

22.68

18.78

agree

18.78

47620

Removal of gallbladder

17.36

24.70

20.64

agree

20.64

47701

Bile duct revision

27.81

36.50

27.81

agree

27.81

47711

Excision of bile duct tumor

19.37

31.38

23.03

agree

23.03

47712

Excision of bile duct tumor

25.44

38.58

30.24

agree

30.24

47715

Excision of bile duct cyst

15.81

32.81

18.80

agree

18.80

47716

Fusion of bile duct cyst

13.83

19.34

16.44

agree

16.44

47720

Fuse gallbladder & bowel

13.38

18.16

15.91

agree

15.91

47721

Fuse upper gi structures

16.08

21.91

19.12

agree

19.12

47740

Fuse gallbladder & bowel

15.54

20.63

18.48

agree

18.48

47741

Fuse gallbladder & bowel

17.95

24.39

21.34

agree

21.34

47760

Fuse bile ducts and bowel

21.74

21.91

25.85

agree

25.85

47765

Fuse liver ducts & bowel

20.93

30.62

24.88

agree

24.88

47780

Fuse bile ducts and bowel

22.29

26.86

26.50

agree

26.50

47785

Fuse bile ducts and bowel

26.23

36.32

31.18

agree

31.18

47800

Reconstruction of bile ducts

19.60

26.89

23.30

agree

23.30

47801

Placement, bile duct support

12.76

23.47

15.17

agree

15.17

47802

Fuse liver duct & intestine

18.13

34.11

21.55

agree

21.55

47900

Suture bile duct injury

16.74

20.50

19.90

agree

19.90

48000

Drainage of abdomen

14.91

40.79

28.07

agree

28.07

48001

Placement of drain, pancreas

18.83

55.20

35.45

agree

35.45

48005

Resect/debride pancreas

22.40

57.70

42.17

agree

42.17

48020

Removal of pancreatic stone

14.22

23.50

15.70

agree

15.70

48100

Biopsy of pancreas

11.08

14.57

12.23

agree

12.23

48120

Removal of pancreas lesion

14.36

26.05

15.85

agree

15.85

48140

Partial removal of pancreas

20.78

28.60

22.94

agree

22.94

48145

Partial removal of pancreas

21.76

34.32

24.02

agree

24.02

48146

Pancreatectomy

23.91

45.57

26.40

agree

26.40

48148

Removal of pancreatic duct

15.71

25.00

17.34

agree

17.34

48150

Partial removal of pancreas

43.48

54.73

48.00

agree

48.00

48150

Partial removal of pancreas

43.48

54.75

48.00

agree

48.00

48152

Pancreatectomy

39.63

39.63

43.75

agree

43.75

48153

Pancreatectomy

43.38

54.73

47.89

agree

47.89

48154

Pancreatectomy

39.95

51.80

44.10

agree

44.10

48155

Removal of pancreas

22.32

44.70

24.64

agree

24.64

48180

Fuse pancreas and bowel

22.39

32.52

24.72

agree

24.72

48500

Surgery of pancreas cyst

13.84

18.99

15.28

agree

15.28

48510

Drain pancreatic pseudocyst

12.96

16.08

14.31

agree

14.31

48520

Fuse pancreas cyst and bowel

14.12

19.68

15.59

agree

15.59

48540

Fuse pancreas cyst and bowel

17.86

21.28

19.72

agree

19.72

48545

Pancreatorrhaphy

16.47

33.39

18.18

agree

18.18

48547

Duodenal exclusion

23.40

41.76

25.83

agree

25.83

49000

Exploration of abdomen

11.68

13.42

11.68

agree

11.68

49002

Reopening of abdomen

10.49

12.67

10.49

agree

10.49

49010

Exploration behind abdomen

12.28

15.06

12.28

agree

12.28

49020

Drain abdominal abscess

16.79

28.33

20.73

increase

22.84

49040

Drain, open, abdom abscess

9.94

23.60

12.27

increase

13.52

49060

Drain, open, retrop abscess

11.66

19.52

14.40

increase

15.86

49085

Remove abdomen foreign body

8.93

14.23

11.03

increase

12.14

49200

Removal of abdominal lesion

10.25

12.19

10.25

agree

10.25

49201

Removal of abdominal lesion

14.84

16.27

14.84

agree

14.84

49215

Excise sacral spine tumor

22.36

24.96

33.50

agree

33.50

49215

Excise sacral spine tumor

22.36

30.00

33.50

agree

33.50

49220

Multiple surgery, abdomen

14.88

17.39

14.88

agree

14.88

49255

Removal of omentum

11.14

13.42

11.14

agree

11.14

49320

Diag laparo separate proc

5.10

5.95

5.10

agree

5.10

49321

Laparoscopy; biopsy

5.40

N/A

5.40

agree

5.40

49322

Laparoscopy; aspiration

5.70

N/A

5.70

agree

5.70

49421

Insert abdominal drain

5.54

6.99

5.54

agree

5.54

49422

Remove perm cannula/catheter

6.25

6.35

6.25

agree

6.25

49425

Insert abdomen-venous drain

11.37

13.82

11.37

agree

11.37

49426

Revise abdomen-venous shunt

9.63

11.10

9.63

agree

9.63

49428

Ligation of shunt

2.38

5.38

6.06

agree

6.06

49429

Removal of shunt

7.40

9.57

7.40

agree

7.40

49495

Repair inguinal hernia, init

5.89

6.96

CPT

CPT

5.89

49495

Repair inguinal hernia, init

5.89

12.50

CPT

CPT

5.89

49496

Repair inguinal hernia, init

8.79

10.56

CPT

CPT

8.79

49496

Repair inguinal hernia, init

8.79

14.00

CPT

CPT

8.79

49500

Repair inguinal hernia

4.68

7.61

5.48

agree

5.48

49501

Repair inguinal hernia, init

7.58

9.26

8.88

agree

8.88

49505

Repair inguinal hernia

6.49

8.31

7.60

agree

7.60

49505

Repair inguinal hernia

6.49

11.50

7.60

agree

7.60

49507

Repair inguinal hernia

8.17

11.38

9.57

agree

9.57

49520

Rerepair inguinal hernia

8.22

11.02

9.63

agree

9.63

49521

Repair inguinal hernia, rec

10.22

13.97

11.97

agree

11.97

49525

Repair inguinal hernia

7.32

8.36

8.57

agree

8.57

49540

Repair lumbar hernia

8.87

8.52

10.39

agree

10.39

49550

Repair femoral hernia

7.37

8.36

8.63

agree

8.63

49553

Repair femoral hernia, init

8.06

10.31

9.44

agree

9.44

49555

Repair femoral hernia

7.71

8.50

9.03

agree

9.03

49557

Repair femoral hernia, recur

9.52

11.82

11.15

agree

11.15

49560

Repair abdominal hernia

9.88

11.69

11.57

agree

11.57

49561

Repair incisional hernia

12.17

15.67

14.25

agree

14.25

49565

Rerepair abdominal hernia

9.88

14.03

11.57

agree

11.57

49566

Repair incisional hernia

12.30

16.43

14.40

agree

14.40

49570

Repair epigastric hernia

4.86

7.00

5.69

agree

5.69

49572

Repair epigastric hernia

5.75

9.77

6.73

agree

6.73

49580

Repair umbilical hernia

3.51

5.71

4.11

agree

4.11

49582

Repair umbilical hernia

5.68

9.99

6.65

agree

6.65

49585

Repair umbilical hernia

5.32

5.71

6.23

agree

6.23

49587

Repair umbilical hernia

6.46

9.34

7.56

agree

7.56

49590

Repair abdominal hernia

7.29

9.54

8.54

agree

8.54

49605

Repair umbilical lesion

22.66

97.62

76.00

decrease

22.66

49606

Repair umbilical lesion

18.60

21.31

18.60

agree

18.60

49650

Laparo hernia repair initial

6.27

7.66

6.27

agree

6.27

49651

Laparo hernia repair recur

8.24

7.88

8.24

agree

8.24

49900

Repair of abdominal wall

12.28

16.92

12.28

agree

12.28

49905

Omental flap

6.55

17.79

CPT

CPT

6.55

50200

Biopsy of kidney

2.63

N/A

CPT

CPT

2.63

50230

Removal of kidney

22.07

N/A

CPT

CPT

22.07

51595

Remove bladder/revise tract

37.14

N/A

37.14

agree

37.14

51596

Remove bladder/create pouch

39.52

N/A

39.52

agree

39.52

52300

Cystoscopy and treatment

5.31

WD

(e)

(a)

5.31

52327

Cystoscopy, inject material

5.19

WD

(e)

(a)

5.19

52340

Cystoscopy and treatment

9.68

WD

(e)

(a)

9.68

56515

Destruction, vulva lesion(s)

1.88

3.09

2.76

agree

2.76

56740

Remove vagina gland lesion

3.76

5.74

4.57

agree

4.57

57100

Biopsy of vagina

0.97

1.90

1.20

agree

1.20

57130

Remove vagina lesion

2.43

5.67

2.43

agree

2.43

57292

Construct vagina with graft

13.09

N/A

13.09

agree

13.09

57307

Fistula repair & colostomy

15.93

20.24

15.93

agree

15.93

57410

Pelvic examination

1.75

4.08

1.75

agree

1.75

57505

Endocervical curettage

1.14

0.97

1.14

agree

1.14

57555

Remove cervix/repair vagina

8.95

WD

(e)

(a)

8.95

58150

Total hysterectomy

15.24

17.75

15.24

agree

15.24

58152

Total hysterectomy

15.09

20.60

20.60

agree

20.60

58260

Vaginal hysterectomy

12.20

12.98

12.98

agree

12.98

58262

Vaginal hysterectomy

13.99

17.88

14.77

agree

14.77

58263

Vaginal hysterectomy

15.28

21.26

16.06

agree

16.06

58267

Hysterectomy & vagina repair

15.00

17.55

17.04

agree

17.04

58270

Hysterectomy & vagina repair

13.48

15.58

14.26

agree

14.26

58275

Hysterectomy/revise vagina

14.98

N/A

15.76

agree

15.76

58280

Hysterectomy/revise vagina

15.41

N/A

17.01

agree

17.01

58285

Extensive hysterectomy

18.57

N/A

22.26

agree

22.26

58323

Sperm washing

0.23

0.55

0.23

agree

0.23

58400

Suspension of uterus

6.36

11.68

6.36

agree

6.36

58600

Division of fallopian tube

3.84

4.60

5.60

agree

5.60

58605

Division of fallopian tube

3.34

4.60

5.00

agree

5.00

58611

Ligate oviduct(s) add-on

0.63

N/A

1.45

agree

1.45

58700

Removal of fallopian tube

6.49

11.68

12.05

agree

12.05

58740

Revise fallopian tube(s)

5.83

11.29

14.00

agree

14.00

58805

Drainage of ovarian cyst(s)

5.88

11.68

5.88

agree

5.88

58820

Drain ovary abscess, open

4.22

6.03

4.22

agree

4.22

58825

Transposition, ovary(s)

6.13

11.68

10.98

agree

10.98

58920

Partial removal of ovary(s)

6.78

11.68

11.36

agree

11.36

58950

Resect ovarian malignancy

15.27

16.93

16.93

agree

16.93

58951

Resect ovarian malignancy

21.81

28.99

22.38

agree

22.38

59150

Treat ectopic pregnancy

6.89

11.67

11.67

agree

11.67

59151

Treat ectopic pregnancy

7.86

11.49

11.49

agree

11.49

59812

Treatment of miscarriage

3.25

4.01

4.01

agree

4.01

59870

Evacuate mole of uterus

4.28

5.00

6.01

agree

6.01

60100

Biopsy of thyroid

0.97

1.88

1.56

agree

1.56

60220

Partial removal of thyroid

10.53

11.82

11.90

agree

11.90

60220

Partial removal of thyroid

10.53

14.24

11.90

agree

11.90

60252

Removal of thyroid

18.20

22.32

20.57

agree

20.57

60254

Extensive thyroid surgery

23.88

27.43

26.99

agree

26.99

60260

Repeat thyroid surgery

15.46

18.83

17.47

agree

17.47

60270

Removal of thyroid

17.94

23.05

20.27

agree

20.27

60271

Removal of thyroid

14.89

18.68

16.83

agree

16.83

60280

Remove thyroid duct lesion

6.08

WD

(e)

(a)

6.08

60540

Explore adrenal gland

17.03

20.53

17.03

agree

17.03

60545

Explore adrenal gland

19.88

25.66

19.88

agree

19.88

62263

Lysis epidural adhesions

6.14

7.20

7.20

(b)

6.14

62310

Inject spine c/t

1.91

1.95

2.20

(b)

1.91

62311

Inject spine l/s (cd)

1.54

1.57

1.78

(b)

1.54

62318

Inject spine w/cath, c/t

2.04

2.26

2.35

(b)

2.04

62319

Inject spine w/cath l/s (cd)

1.87

1.88

2.15

(b)

1.87

65855

Laser surgery of eye

4.30

N/A

3.85

agree

3.85

66170

Glaucoma surgery

12.16

WD

(e)

(a)

12.16

66172

Incision of eye

15.04

WD

(e)

(a)

15.04

66180

Implant eye shunt

14.55

N/A

14.55

agree

14.55

66986

Exchange lens prosthesis

12.28

N/A

12.28

agree

12.28

67028

Injection eye drug

2.52

N/A

2.52

agree

2.52

67108

Repair detached retina

20.82

WD

(e)

(a)

20.82

67218

Treatment of retinal lesion

13.52

N/A

18.53

agree

18.53

67904

Repair eyelid defect

6.26

N/A

6.26

agree

6.26

69000

Drain external ear lesion

1.45

WD

(e)

(a)

1.45

69005

Drain external ear lesion

2.11

WD

(e)

(a)

2.11

69020

Drain outer ear canal lesion

1.48

WD

(e)

(a)

1.48

69100

Biopsy of external ear

0.81

WD

(e)

(a)

0.81

69105

Biopsy of external ear canal

0.85

WD

(e)

(a)

0.85

69110

Remove external ear, partial

3.44

WD

(e)

(a)

3.44

69120

Removal of external ear

4.05

WD

(e)

(a)

4.05

69140

Remove ear canal lesion(s)

7.97

WD

(e)

(a)

7.97

69145

Remove ear canal lesion(s)

2.62

WD

(e)

(a)

2.62

69150

Extensive ear canal surgery

13.43

WD

(e)

(a)

13.43

69155

Extensive ear/neck surgery

20.80

WD

(e)

(a)

20.80

69200

Clear outer ear canal

0.77

WD

(e)

(a)

0.77

69205

Clear outer ear canal

1.20

WD

(e)

(a)

1.20

69210

Remove impacted ear wax

0.61

WD

(e)

(a)

0.61

69220

Clean out mastoid cavity

0.83

WD

(e)

(a)

0.83

69222

Clean out mastoid cavity

1.40

WD

(e)

(a)

1.40

69300

Revise external ear

6.36

WD

(e)

(a)

6.36

69310

Rebuild outer ear canal

10.79

WD

(e)

(a)

10.79

69320

Rebuild outer ear canal

16.96

WD

(e)

(a)

16.96

69400

Inflate middle ear canal

0.83

WD

(e)

(a)

0.83

69401

Inflate middle ear canal

0.63

WD

(e)

(a)

0.63

69405

Catheterize middle ear canal

2.63

WD

(e)

(a)

2.63

69410

Inset middle ear (baffle)

0.33

WD

(e)

(a)

0.33

69420

Incision of eardrum

1.33

WD

(e)

(a)

1.33

69421

Incision of eardrum

1.73

WD

(e)

(a)

1.73

69424

Remove ventilating tube

0.85

WD

(e)

(a)

0.85

69433

Create eardrum opening

1.52

WD

(e)

(a)

1.52

69436

Create eardrum opening

1.96

WD

(e)

(a)

1.96

69440

Exploration of middle ear

7.57

WD

(e)

(a)

7.57

69450

Eardrum revision

5.57

WD

(e)

(a)

5.57

69501

Mastoidectomy

9.07

WD

(e)

(a)

9.07

69502

Mastoidectomy

12.38

WD

(e)

(a)

12.38

69505

Remove mastoid structures

12.99

WD

(e)

(a)

12.99

69511

Extensive mastoid surgery

13.52

WD

(e)

(a)

13.52

69530

Extensive mastoid surgery

19.19

WD

(e)

(a)

19.19

69535

Remove part of temporal bone

36.14

WD

(e)

(a)

36.14

69540

Remove ear lesion

1.20

WD

(e)

(a)

1.20

69550

Remove ear lesion

10.99

WD

(e)

(a)

10.99

69552

Remove ear lesion

19.46

WD

(e)

(a)

19.46

69554

Remove ear lesion

33.16

WD

(e)

(a)

33.16

69601

Mastoid surgery revision

13.24

WD

(e)

(a)

13.24

69602

Mastoid surgery revision

13.58

WD

(e)

(a)

13.58

69603

Mastoid surgery revision

14.02

WD

(e)

(a)

14.02

69604

Mastoid surgery revision

14.02

WD

(e)

(a)

14.02

69605

Remove mastoid structures

18.49

WD

(e)

(a)

18.49

69610

Repair of eardrum

4.43

WD

(e)

(a)

4.43

69620

Repair of eardrum

5.89

WD

(e)

(a)

5.89

69631

Rebuild eardrum structures

9.86

WD

(e)

(a)

9.86

69632

Rebuild eardrum structures

12.75

WD

(e)

(a)

12.75

69633

Rebuild eardrum structures

12.10

WD

(e)

(a)

12.10

69635

Repair eardrum structures

13.33

WD

(e)

(a)

13.33

69636

Rebuild eardrum structures

15.22

WD

(e)

(a)

15.22

69637

Rebuild eardrum structures

15.11

WD

(e)

(a)

15.11

69641

Revise middle ear & mastoid

12.71

WD

(e)

(a)

12.71

69642

Revise middle ear & mastoid

16.84

WD

(e)

(a)

16.84

69643

Revise middle ear & mastoid

15.32

WD

(e)

(a)

15.32

69644

Revise middle ear & mastoid

16.97

WD

(e)

(a)

16.97

69645

Revise middle ear & mastoid

16.38

WD

(e)

(a)

16.38

69646

Revise middle ear & mastoid

17.99

WD

(e)

(a)

17.99

69650

Release middle ear bone

9.66

WD

(e)

(a)

9.66

69660

Revise middle ear bone

11.90

WD

(e)

(a)

11.90

69661

Revise middle ear bone

15.74

WD

(e)

(a)

15.74

69662

Revise middle ear bone

15.44

WD

(e)

(a)

15.44

69666

Repair middle ear structures

9.75

WD

(e)

(a)

9.75

69667

Repair middle ear structures

9.76

WD

(e)

(a)

9.76

69670

Remove mastoid air cells

11.51

WD

(e)

(a)

11.51

69676

Remove middle ear nerve

9.52

WD

(e)

(a)

9.52

69700

Close mastoid fistula

8.23

WD

(e)

(a)

8.23

69711

Remove/repair hearing aid

10.44

WD

(e)

(a)

10.44

69720

Release facial nerve

14.38

WD

(e)

(a)

14.38

69725

Release facial nerve

25.38

WD

(e)

(a)

25.38

69740

Repair facial nerve

15.96

WD

(e)

(a)

15.96

69745

Repair facial nerve

16.69

WD

(e)

(a)

16.69

69801

Incise inner ear

8.56

WD

(e)

(a)

8.56

69802

Incise inner ear

13.10

WD

(e)

(a)

13.10

69805

Explore inner ear

13.82

WD

(e)

(a)

13.82

69806

Explore inner ear

12.35

WD

(e)

(a)

12.35

69820

Establish inner ear window

10.34

WD

(e)

(a)

10.34

69840

Revise inner ear window

10.26

WD

(e)

(a)

10.26

69905

Remove inner ear

11.10

WD

(e)

(a)

11.10

69910

Remove inner ear & mastoid

13.63

WD

(e)

(a)

13.63

69915

Incise inner ear nerve

21.23

WD

(e)

(a)

21.23

69930

Implant cochlear device

16.81

WD

(e)

(a)

16.81

69950

Incise inner ear nerve

25.64

WD

(e)

(a)

25.64

69955

Release facial nerve

27.04

WD

(e)

(a)

27.04

69960

Release inner ear canal

27.04

WD

(e)

(a)

27.04

69970

Remove inner ear lesion

30.04

WD

(e)

(a)

30.04

69990

Microsurgery add-on

3.47

N/A

3.47

agree

3.47

72275

Epidurography

0.76

0.83

0.83

(b)

0.76

76005

Fluoroguide for spine inject

0.60

0.60

10.60

agree

0.60

76065

X-rays, bone evaluation

0.28

0.60

0.70

agree

0.70

76090

Mammogram, one breast

0.58

0.64

0.70

agree

0.70

76091

Mammogram, both breasts

0.69

0.76

0.87

agree

0.87

76095

Stereotactic breast biopsy

1.59

3.58

1.59

agree

1.59

88170

Fine needle aspiration

1.27

3.28

1.27

agree

1.27

88171

Fine needle aspiration

1.27

2.63

1.27

agree

1.27

90901

Biofeedback train, any meth

0.41

N/A

0.41

agree

0.41

90911

Biofeedback peri/uro/rectal

0.89

N/A

0.89

agree

0.89

90935

Hemodialysis, one evaluation

1.22

N/A

CPT

CPT

1.22

90937

Hemodialysis, repeated eval

2.11

N/A

CPT

CPT

2.11

90945

Dialysis, one evaluation

1.28

N/A

CPT

CPT

1.28

90947

Dialysis, repeated eval

2.16

N/A

CPT

CPT

2.16

90989

Dialysis training, complete

0.00

N/A

CPT

CPT

0.00

90993

Dialysis training, incompl

0.00

N/A

CPT

CPT

0.00

90997

Hemoperfusion

1.84

N/A

CPT

CPT

1.84

92018

New eye exam & treatment

1.51

N/A

2.50

agree

2.50

93350

Echo transthoracic

0.78

N/A

1.48

agree

1.48

94640

Airway inhalation treatment

0.00

N/A

0.00

agree

0.00

94664

Aerosol or vapor inhalations

0.00

N/A

CPT

CPT

0.00

94665

Aerosol or vapor inhalations

0.00

N/A

CPT

CPT

0.00

96100

Psychological testing

0.00

2.00

(a)

agree

0.00

96105

Assessment of aphasia

0.00

2.00

(a)

agree

0.00

96110

Developmental test, lim

0.00

2.00

(a)

agree

0.00

96115

Neurobehavior status exam

0.00

2.20

(a)

agree

0.00

96117

Neuropsych test battery

0.00

2.20

(a)

agree

0.00

97542

Wheelchair mngmnt training

0.25

0.45

0.45

agree

0.45

99233

Subsequent hospital care

1.51

N/A

1.51

agree

1.51

99273

Confirmatory consultation

1.19

N/A

1.19

agree

1.19

99274

Confirmatory consultation

1.73

N/A

1.73

agree

1.73

99291

Critical care, first hour

3.60

4.00

4.00

agree

4.00

99291

Critical care, first hour

3.60

5.50

4.00

agree

4.00

99291

Critical care, first hour

3.60

N/A

4.00

agree

4.00

99292

Critical care, addl 30 min

1.80

2.00

2.00

agree

2.00

99292

Critical care, addl 30 min

1.80

2.77

2.00

agree

2.00

99292

Critical care, addl 30 min

1.80

N/A

2.00

agree

2.00

99295

Neonatal critical care

16.00

N/A

16.00

agree

16.00

99296

Neonatal critical care

8.00

N/A

8.00

agree

8.00

99297

Neonatal critical care

4.00

N/A

4.00

agree

4.00

99298

Neonatal critical care

2.75

N/A

2.75

agree

2.75

99436

Attendance, birth

1.50

N/A

1.50

agree

1.50

99440

Newborn resuscitation

2.93

N/A

2.93

agree

2.93

G0127

Trim nail(s)

0.11

N/A

(a)

(a)

0.11

B. Discussion of Comments by Clinical Area

1. Vascular Surgery

Comment:

The Society for Vascular Surgery (SVS) and the North American Chapter of the International Society for Cardiovascular Surgery requested increases in work RVUs for 95 codes. Both groups commented that vascular surgery procedures were undervalued in the original Harvard Study and that only a small number of these RVUs have been adjusted since that time.

The SVS's recommendations were based on surveys, a full RUC survey of 39 higher volume codes and minisurveys for 56 less frequently performed codes. (The full and minisurveys included estimates for each code of pre-, intra-, and postservice times and visits as well as estimates of physician work. The effect of these recommendations would be to correct current rank-order anomalies, while avoiding creation of new rank-order anomalies.) The SVS used a building-block approach to validate the survey results for each of their codes.

RUC Recommendation

Of the 95 codes, the RUC recommended increases for 91 codes, a decrease for 1 code and no changes for 3 codes. In 60 percent of cases, the RUC recommendations to increase the work RVUs were based on physician surveys. The recommendations were based on either the 25th percentile or the median of survey responses. In almost all other cases, the RUC recommendation for a specific code work RVU was based on the work value of another comparable code. The building-block approach was used only to corroborate findings from the surveys or validate a comparison to another procedure. The following are the RUC recommendations for the codes submitted. (Please note that throughout this document the value in parentheses represents the RUC-recommended work RVUs unless they are shown in columns.)

CPT codes

Work RVUs

Family 1 Aneurysm Repairs in Abdomen

35111

25.00

35131

25.00

35112

30.00

35132

30.00

35121

30.00

35122

35.00

35082

38.50

35103

40.50

35092

45.00

Family 2 Bypass Grafts in the Abdomen

35665

21.00

35663

22.00

35565

23.20

35563

24.20

35636

29.50

35536

31.70

35560

32.00

35631

34.00

35531

36.20

Family 3 Embolectomy/Thrombectomy in the Abdomen

34401

25.00

34151

25.00

34451

27.00

Family 4 Endarterectomy in the Abdomen

35351

23.00

35331

26.20

35361

28.20

35363

30.20

Family 5 Repair Blood Vessels in the Abdomen

37660

21.00

37617

22.06

35221

24.39

35281

28.00

35251

30.20

Family 6 Explorations, Revisions, Other in Chest & Abdomen

35189

28.00

35182

30.00

35905

31.25

35907

35.00

Family 7 Extra-anatomic Bypass Grafts

35661

19.00

35650

19.00

35621

20.00

35558

21.20

35511

21.20

35518

21.20

35623

24.00

35521

22.20

35654

25.00

35533

28.00

Family 8 Arterial Bypass Grafts in Extremities

35666

22.19

35671

19.23

35571

24.06

35587

24.75

Family 9 Embolectomy/Thrombectomy by Extremity Incision

34490

9.86

34111

10.00

34201

10.03

34101

10.00

34421

12.00

34203

16.50

Family 10 Aneurysm Repairs in the Extremity

35045

17.57

35011

18.00

35141

20.00

35013

22.00

35151

22.64

35142

23.30

35152

25.62

Family 11 Endarterectomy of Extremity Arteries

35371

14.72

35321

16.00

35372

18.00

35355

18.50

Family 12 Arteriovenous Fistula Repairs in the Extremities

35190

No change in work RVUs

35184

18.00

Family 13 Peripheral Artery and Vein Ligations

35721

7.18

37650

7.80

35741

8.00

37618

No change in work RVUs

37565

10.88

37600

11.25

35701

8.50

37605

13.11

37615

No change in work RVUs

Family 14 Vessel/Repairs in Extremities and Neck

35201

16.14

35206

13.25

35226

14.50

35266

14.91

35261

17.80

35286

16.16

35236

17.11

35231

20.00

35256

18.36

Family 15 Reconstruction for Chronic Venous Disease

34501

16.00

34520

17.95

34510

18.95

34530

16.64 (decrease)

Family 16 Repairs, Bypass Grafts, Endarterectomies in the Chest

35276

24.25

35246

26.45

35626

27.75

35526

29.95

35311

27.00

Family 17 Ligation or Biopsy of Temporal Artery

37609

3.00

Family 18 Untitled

35081

28.01

35556

21.76

The RUC recommended the following codes be submitted to the CPT Editorial Panel for further consideration: 35381, 35541, 35546, 35551, 35582, 35641, 35646, 35840, 35860, 37615, 37618, 37700, 37730, 37735, 37760, 37785.

HCFA Proposal:

We have reviewed and propose to accept all of the RUC recommendations for the vascular surgery codes. We believe that relativity is maintained, and the RVUs more appropriately reflect the work involved.

2. General Surgery/Colon and Rectal Surgery

Comment:

The American Society of General Surgeons (ASGS) submitted 55 codes it believed to be undervalued. The ASGS recommended work RVUs for each service. After submitting the codes, the specialty society ultimately chose not to pursue review of RVUs for the following codes under the 5-year review: 20605, 34001, and 29881.

The following codes 49505, 32440, 46320, 46924, 31622, 44140 (no change), 38500, 32480, 37609, 43239, 43638, 60220, 44050, 48150, and 38100 were also submitted for review by other specialty groups and are discussed in other sections. (Note that codes 56305, 56341, 56300, 56340, and 56306 are laparoscopic surgery codes also submitted for review by the specialty group; however, these services were deleted or renumbered by CPT for 2000.)

RUC Recommendation:

The RUC recommended that the work RVUs for the following codes be increased (the RUC-recommended work RVUs are in parentheses):

Code 36489,

Placement of central venous catheter (subclavian, jugular, or other vein (eg, for central venous pressure, hyperalimentation, hemodialysis, or chemotherapy)); percutaneous, age 2 years or under

(2.50) to correct a rank-order anomaly; 60100,

Biopsy thyroid, percutaneous core needle

(1.56), to appropriately reflect the work involved and fit in the range of biopsy codes; and 31600,

Tracheostomy, planned (separate procedure)

(7.18), based on the building-block approach and the comparison to similar procedures.

For the following codes, the RUC stated that there was no compelling evidence provided to support increasing the work RVUs. Therefore, it recommended maintaining the current work RVUs for the following codes: 19100, 88170, 57410, 76095, 88171, 32000, 21800, 46083, 19000, 19125, 45330, 19160, 13101, 11402, 12011, 11642, 27590, 45378, 36625, 45309, 45305, 35081, 19240, 58150, 43246, 19162, and 35556. The RUC also recommended maintaining the current work RVUs for codes 49321 and 49322 because these services had recently been reviewed by the RUC.

The RUC recommended that the following codes be referred to the CPT Editorial Panel for review or clarification: 37720 and 43215.

HCFA Proposal:

We have reviewed and propose to accept all of the RUC recommendations for these surgery codes.

Comment:

The American College of Surgeons (ACS) submitted general surgery codes for review that account for approximately 50 percent of general surgery's Medicare-allowed charges for services categorized as surgery under our “type of service” classification. The procedures are predominantly performed by general surgeons, and they involve the gastrointestinal tract, abdominal organs, thyroid, lymph system, and endocrine system. Requests for review of some of these codes were also submitted by other specialty groups.

In its comments, the ACS emphasized that its analysis determined that the work of codes in general surgery has been systematically undervalued.

The ACS used a building-block approach with panel-assigned intraoperative work intensities for procedures. Preoperative work RVUs were determined based on an assigned intensity multiplied by the number of preservice minutes. The assigned preservice work intensity was below that of an evaluation and management service. A panel of ASC members assigned intraservice work intensity to each code using a scale. The intensity of an evaluation and management service was the low end of the scale, and liver resection services were on the high end of the scale. The ends of the scale were chosen to represent “average” work intensity throughout a procedure. The ACS maintains that the work intensity of any surgical procedure is greater than the work intensity of an evaluation and management service. Postservice work RVUs were calculated using current work RVUs for hospital visits and discounted work RVUs for office visits. Pre, intra-, and postwork RVUs were summed to equal the new work RVUs that the ACS developed for each code.

The ACS assigned over 300 codes to 31 families of similar services (for example, all codes related to hernia repair were in one family). It conducted a traditional RUC survey for 32 codes (either high volume services or the service most representative of the family of codes). A minisurvey, which did not include a respondent-recommended work value, was conducted for the remaining codes, with participation from other specialty groups. The ACS indicated that the survey respondents tended to overvalue codes at the low end of the scale and undervalue codes at the high end of the scale. As a result, ACS recommended using the 25th percentile of survey results at the low end and the 75th percentile for work RVUs at the high end of the scale for fully-surveyed codes. However, they stated that acceptance of these survey results without adjustments to other codes in the family that were not fully surveyed would distort the relativity within and across families. They recommended a regression methodology to extrapolate the fully-surveyed code results to the other codes.

RUC Recommendation:

The RUC workgroup reviewed the data collected for the 32 fully-surveyed ACS codes. It also reviewed the families of services proposed by ACS and modified the families that were too dissimilar to permit appropriate comparison within the family. After the anchor code was reviewed, each family was reviewed to determine whether the change to the anchor code should be applied to the entire family of codes. In some instances the RUC agreed that the recommended change in the anchor code should be extrapolated to the entire family to ensure that rank-order and relativity distortions were not created by a change to the anchor code. In other instances the RUC determined that the recommendation for the anchor code did not apply to the family of codes. In these instances, either new RVUs were recommended or the present work RVUs were maintained. The following are the code-specific RUC recommendations:

CPT codes

Work RVUs

Family 1A & B Thyroid/Endocrine

60220

11.90

60252

20.57

60254

26.99

60260

17.47

60270

20.27

60271

16.83

60540

No change

60545

No change

Family 2 Lymphadenectomy

38740

8.42

38745

11.00

38760

10.88

38765

19.98

Family 3 Lymph Nodes and Lymphatic Channels—Incision/Excision

38300

1.99

38305

6.00

38308

6.45

38500

3.75

38510

6.43

38520

6.67

38525

6.07

38530

7.98

Family 4 Intestines—Excision/Incision

44005

16.23

44010

12.52

44020

13.99

44021

14.08

44025

14.28

44050

14.03

44110

11.81

44111

14.29

44120

17.00

44125

17.54

44130

14.49

44160

18.62

44800

11.23

44820

12.09

Family 5 Intestines—External Fistulization

44300

12.11

44310

15.95

44312

8.02

44314

15.05

44316

21.09

44320

17.64

44340

17.72

44345

15.43

44346

16.99

Family 6 Intestines—Colectomy

Codes 44140, 44143, 44144, 44145, 44146, 44150, 44151, 44152, 44153, 44155, and 44156. The RUC made no changes to any of these codes based on the lack of compelling evidence.

Family 7 intestines—Repair

44602

11.91

44603

15.72

44604

16.03

44605

17.25

44615

15.93

44620

12.20

44625

15.05

44626

25.36

44640

16.65

44650

17.12

44660

16.42

44661

19.07

44680

15.40

44700

16.11

44850

10.74

Family 8 Anus/Rectum—Hemorrhoids/Fistula

45000

3.88

45020

4.05

45100

3.16

45108

4.09

46040

4.26

46045

3.71

46060

4.89

46250

3.89

46255

4.60

46257

5.40

46258

5.73

46260

6.37

46261

7.08

46262

7.50

46270

3.20

46275

3.92

46280

5.14

46288

6.13

46934

3.51

46936

3.69

46945

1.84

46946

2.58

Note:

All of the work RVUs for Family 8 reflect a recommended decrease from the CY 2000 work RVUs.

Family 9 A B &C Anus/Rectum, Anus (destruction)—10-day global

45900

2.61

45905

2.30

45910

2.80

45915

3.14

46221

2.04

46754

2.20

Note:

Based on the lack of compelling evidence, the RUC recommended that no changes be made to the following Family 9 codes: 46083, 46230, 46320, 46935, 46940, 46942, 46900, 46910, 46916, 46917, 46922, and 46924.

Family 10 Anus/Rectum Repair

45505

7.58

45540

16.27

45541

13.40

45550

23.00

45560

10.58

45562

15.38

45563

23.47

45800

17.77

45805

20.78

45820

18.48

45825

21.25

46700

9.13

46750

10.25

46753

8.29

46760

14.43

46761

13.84

46762

12.71

Family 11 Hernia

49500

5.48

49501

8.88

49505

7.60

49507

9.57

49520

9.63

49521

11.97

49525

8.57

49540

10.39

49550

8.63

49553

9.44

49555

9.03

49557

11.15

49560

11.57

49561

14.25

49565

11.57

49566

14.40

49570

5.69

49572

6.73

49580

4.11

49582

6.65

49585

6.23

49587

7.56

49590

8.54

Family 12 A & B Stomach—Gastrectomy and Gastrectomy/Vagotomy

43620

30.04

43621

30.73

43622

32.53

43638

29.00

43639

29.65

43631

22.59

43632

22.59

43633

23.10

43634

25.12

43640

17.02

43641

17.27

Family 13 A & B Stomach—Incision/Excision/Repair

43500

11.05

43501

20.04

43502

23.13

43510

13.08

43520

9.99

43605

11.98

43610

14.60

43611

17.84

43800

13.69

43810

14.65

43820

15.37

43825

19.22

43830

9.53

43832

15.60

43840

15.56

43870

9.69

43842

18.47

43843

18.65

43846

24.05

43847

26.92

43848

29.39

43850

24.72

43855

26.16

43860

25.00

43865

26.52

43880

24.65

Family 14 A Abdomen, Peritoneum, Omentum

The RUC recommended no changes for codes 49000, 49002, 49010, 49200, 49201, 49220, 49255, 49900, 49421, 49422, 49425, 49426, and 49429.

Family 14 B Abdomen, Peritoneum, Omentum

49020

20.73

49040

12.27

49060

14.40

49085

11.03

Family 14 C Abdomen, Peritoneum, Omentum

49428

6.06

Family 15 Appendix

44900

10.14

44950

10.00

44960

12.34

Family 16 Rectum—Proctectomy/Excision

45110

28.00

45112

30.54

45113

30.58

45114

27.32

45116

24.58

45119

30.84

45123

16.71

45126

45.16

45130

16.44

45135

19.28

45160

15.32

45170

11.49

45190

9.74

Family 17 Biliary Tract

47420

19.88

47425

19.83

47460

18.04

47480

10.82

47600

13.58

47605

14.69

47610

18.82

47612

18.78

47620

20.64

47711

23.03

47712

30.24

47715

18.80

47716

16.44

47720

15.91

47721

19.12

47740

18.48

47741

21.34

47760

25.85

47765

24.88

47780

26.50

47785

31.18

47800

23.30

47801

15.17

47802

21.55

47900

19.90

Family 18 Esophagus—Repair/Reconstruction

43320

19.93

43324

20.57

43325

20.06

43326

19.74

43330

19.77

43331

20.13

43340

19.61

43341

20.85

43350

15.78

43351

18.35

43352

15.26

43360

35.70

43361

40.50

43400

21.20

43401

22.09

43405

20.01

43410

13.47

43415

25.00

43420

14.35

43425

21.03

Family 19 Liver

47010

16.01

47015

15.11

47100

11.67

47120

35.50

47122

55.13

47125

49.19

47130

53.35

47300

15.08

47350

19.56

47360

26.92

47361

47.12

47362

18.51

47400

32.49

Family 20 A & B Spleen—Incision/Excision/Repair and Pancreatitis Management

38100

14.50

38101

15.31

38115

15.82

48000

28.07

48001

35.45

48005

42.17

Family 21 Pancreatectomy

48020

15.70

48100

12.23

48120

15.85

48140

22.94

48145

24.02

48146

26.40

48148

17.34

48150

48.00

48152

43.75

48153

47.89

48154

44.10

48155

24.64

48180

24.72

48500

15.28

48510

14.31

48520

15.59

48540

19.72

48545

18.18

48547

25.83

Family 22 Laparoscopy

The RUC recommended no changes to the following codes based on lack of compelling evidence: 43651, 43652, 44200, 44970, 47562, 47563, 47564, 47570, 49320, 49650, and 49651.

The RUC also recommended that the following codes be referred to the CPT Editorial Panel for review and clarification: 36533, 36534, 36535, 49495, and 49496.

HCFA Proposal:

The ACS conducted full surveys of 32 codes, and we agreed with the RUC analysis for most of the 32 codes. For the other codes the ACS did minisurveys that included pre-, intra-, and postservice times as well as the number and type of postservice visits. These minisurveys did not include an estimate of the relative work for the procedure. For this reason, the RUC used an extrapolation methodology to arrive at its work RVU recommendations for all codes that did not have a full RUC survey. To make appropriate extrapolations, the RUC divided all of the general surgery codes into families of related procedures. At least one code in each family was fully surveyed. After the RUC recommended work RVUs for each surveyed code, it applied the percent change for that code to all of the other codes in the family. When more than one code was fully surveyed within a family of services, the RUC extrapolated the percentage from the fully surveyed code that would produce the least increase in work RVUs.

The validity of this extrapolation methodology relies on at least two things—first, that the relative work values of all codes in the family were correct before the extrapolation (or else the extrapolation perpetuates and magnifies any pre-existing anomalies), and second, that the relative misvaluation of each code in a family is similar.

We did an analysis of all the families of codes in the general surgery group to determine whether the relative valuations in the 2001 physician fee schedule contained any anomalies. If any anomalies existed, we reviewed the RUC recommendations to determine whether the anomalies were addressed by the RUC recommendations. If the anomalies were not corrected, we took steps to correct them.

We also analyzed all of the recommended values for general surgery to ensure that the percentage changes for each family were appropriate. To determine if the extrapolation for each family was correct, we compared each extrapolated code to codes in other families, and to codes in other specialties. We compared extrapolated codes to codes whose current or RUC recommended work RVUs (from the 5-year-review) were similar to the extrapolated code. We then compared the preservice, intraservice, and postservice physician times as well as the number of postoperative visits. In addition, we generally determined whether the survey vignette was typical for the procedure. The following is an example of our review of the general surgery codes. Code 35132 (

Direct repair of aneurysm, false aneurysm, or excision (partial or total) and graft insertion, with or without patch graft; for ruptured aneurysm, iliac artery (common, internal, external

) (30.00 work RVUs) with a preservice time of 67 minutes, intraservice time of 180 minutes, seven hospital visits, and three office visits is similar to codes 47712 (

Excision of bile duct tumor, with or without primary repair of bile duct; intrahepatic

) (30.24 work RVUs) with a preservice time of 75 minutes, intraservice time of 210 minutes, one intensive care unit visit, nine hospital visits, and three office visits and 43638 (

Gastrectomy, partial, proximal, thoracic or abdominal approach and esophagogastrostomy with vagotomy

) (29.00 work RVUs ) with a preservice time of 75 minutes, intraservice time of 210 minutes, 10 hospital visits, and 4 office visits. A review of these codes demonstrates the similarity in preservice and intraservice time and the proposed RVUs maintain relativity across surgical specialties.

Upon completion of this analysis, we propose to accept the RUC recommendations for the following families of services:

Family 1A and 1B Thyroid and Endocrine.

Family 3 Lymph Nodes and Lymphatic Channels—Incision/Excision.

Family 4 Intestines—Excision/Incision.

Family 5 Intestines—External Fistulization.

Family 9 Anus/Rectum—10-day global period.

Family 10 Anus/Rectum—Repair.

Family 11 Hernia.

Family 12 Stomach—Gastrectomy/Vagotomy.

Family 13 Stomach—Incision/Excision/Repair.

Family 14A and C Abdomen, Peritoneum, Omentum.

Family 15 Appendectomy.

Family 16 Rectum-Proctectomy/Excision.

Family 17 Biliary Tract.

Family 18 Esophagus—Repair/Reconstruction.

Family 19 Liver.

Family 20 Pancreas/Spleen—Incision/Excision/Repair.

Family 21 Pancreatectomy.

Family 22 Laparoscopy.

For the above families, adopting the RUC-recommended RVUs maintains relativity of the codes based upon a comparison of the codes to procedures in other families and within the family.

For other families of services, the extrapolation methodology inappropriately values codes or does not address current rank-order anomalies. Application of the percentage increases derived from the RUC's extrapolation methodology would only exacerbate any current rank-order anomalies within families. Below, we have outlined, for each family of services, our proposed work RVUs to rectify these problems.

Family 2 Lymphadenectomy

The RUC recommended an increase in work RVUs for the fully surveyed code 38745 (

Axillary lymphadenectomy; complete

) from 8.84 to 11.0 RVUs based on comparisons with codes 60210 (

Partial thyroid lobectomy, unilateral, with or without isthmusectomy

), and 32100 (

Thoracotomy, major with exploration and biopsy

). We disagree. Although codes 38745 and 60210 are performed in the outpatient setting and 32100 is not, code 38745 requires more postoperative wound care. Additionally, the RUC compared 38745 to the pre-5-year review value of 32100. Subsequently the RUC reviewed code 32100 for the 5-year review and is recommending an RVU increase to 15.24 RVUs. Because the intraservice times for codes 38745 and 32100 are identical and 38745 requires more postoperative wound care, a clear rank order anomaly would exist if 38745 was valued at 11.00 work RVUs and 32100 was valued at 15.24 work RVUs. Therefore, we are assigning the median survey RVUs of 13.00 to code 38745. We would also note that the survey RVU spread from the 25th percentile to the 75th percentile ranged from 12.15 to 14.29 RVUs, which is relatively small. An RVU of 13.00 places code 38745 in the correct rank order to the comparison codes. To maintain relativity within this family, we are extrapolating the 47 percent increase in work RVUs of code 38745 to codes 38740 (

Axillary lymphadenectomy; superficial

) and 38760 (

Inguinofemoral lymphadenectomy, superficial, including Cloquets node (separate procedure)

) for proposed work RVUs of 10.02 and 12.94, respectively. However, code 38765 (

Inguinofemoral lymphadenectomy, superficial, in continuity with pelvic lymphadenectomy, including external iliac, hypogastric, and obturator nodes (separate procedure)

) represents a rank-order anomaly as it is currently valued too high relative to the other codes in the family. Therefore, we are accepting

the RUC recommendation for code 38765 of 19.98 work RVUs.

Family 6 Colectomy

The RUC recommended no change in the work RVUs for this family of codes based on lack of compelling evidence for changing the RVUs of the fully surveyed code 44140 (

Partial colectomy

). Moreover, the intraservice time for code 44140 had not changed since the last 5-year review. Additionally, the RUC compared code 44140 to code 32480 (

Removal of lung, other than total pneumonectomy; single lobe (lobectomy)

) and code 50230 (

Nephrectomy, including partial ureterectomy, any approach including rib resection; radical, with regional lymphadenectomy and/or vena caval thrombectomy

) that have similar work RVUs to 44140 and were believed to be longer, more intense procedures with more postoperative care. We disagree with this recommendation. If the RVUs for procedures in this family are not changed, the procedures will be significantly undervalued compared to other general surgery codes (Family 5 and Family 7) and vascular surgery codes. As an example, we note that the RUC-recommended work RVU for code 44153

Colectomy, total, abdominal, without proctectomy; with rectal mucosectomy, ileoanal anastomosis, creation of ileal reservoir (S or J), with or without loop,

will significantly undervalue this code compared to code 45113,

Proctectomy, partial, with rectal mucosectomy, ileoanal anastomosis, creation of ileal reservoir (S or J), with our without loop ileostomy,

thus creating a rank-order anomaly.

We compared code 44140 to code 32480 for which the RUC is recommending a work RVU increase to 23.75. These procedures have similar intraservice times, and the postoperative visits show that although the initial care required for code 32480 is more intense, the length of stay for code 44140 is frequently longer. We also compared code 44140 to codes 37617,

Ligation, major artery (eg post-traumatic, rupture); abdomen,

and 35221,

Repair blood vessel, direct; intra-abdominal.

Code 37617, for which the RUC recommended work RVUs of 22.06, is an emergency operation with a slightly shorter intraservice time and shorter hospital stay. Code 35221, which has RUC-recommended work RVUs of 24.39, is also an emergency operation with an intraservice time and length of stay identical to code 44140. Based on these comparisons, we believe that the survey's 25th percentile work RVUs of 21.00 are appropriate and correctly rank code 44140 to the comparison procedures. This increase is 14 percent greater than the current work RVUs and, with the exception of the two codes discussed below, applying this 14 percent increase to the other codes in this family will place them in proper relationship to other comparable procedures.

Family 6 contains two current rank-order anomalies: code 44151,

Colectomy, total, abdominal, without proctectomy; with continent ileostomy,

has lower work RVUs than code 44150,

Colectomy, total, abdominal, without proctectomy; with ileostomy or ileoproctostomy,

and 44156,

Colectomy, total, abdominal, with proctectomy; with continent ileostomy,

has lower work RVUs than code 44155, Colectomy, total, abdominal, with proctectomy; with ileostomy. Code 44151 is identical to code 44150, and code 44156 is identical to code 44155, except that codes 44151 and 44156 involve the creation of a “continent ileostomy” instead of an “ileostomy or ileoproctostomy.” The work of creating a “continent ileostomy” is greater than the work of creating an “ileostomy or ileoproctostomy.” To correct this rank-order anomaly, we applied the 14 percent increase discussed above to codes 44150 and 44155. Next, we determined the proper incremental increase in work for creation of a “continent ileostomy” by looking to codes 44310,

Ileostomy or jejunostomy, non-tube (separate procedure),

and 44316,

Continent Ileostomy (Kock procedure) (separate procedure),

because the work RVUs of 44316 are the same as the work RVUs of 44310 with the addition of creating a continent ileostomy. We subtracted the RUC-recommended work RVUs of 15.95 for code 44310 from the RUC-recommended work RVUs of 21.09 for code 44316 and divided by 50 percent (50 percent approximates the intraservice portion of the extra work). This resulted in work RVUs of 2.57 that we increased by 14 percent to yield work RVUs of 2.93. We then added 2.93 work RVUs to the RVUs for codes 44150 and 44155 to yield proposed work RVUs of 26.88 for code 44151 and 30.79 for code 44156.

In summary, we propose the following work RVUs for the codes in this family:

Code

Work RVUs

44140

21.00

44143

22.99

44144

21.53

44145

26.42

44146

27.54

44150

23.95

44151

26.88

44152

27.83

44153

30.59

44155

27.86

44156

30.79

With these assigned work RVUs, we believe that Family 6 is ranked appropriately in relation to other general and vascular surgery codes.

Family 7 Intestines—Repair

The RUC recommended an increase of 14 percent for all work RVUs in this family based on a recommended increase in a fully surveyed code 44604

(Suture of large intestine (colorrhaphy) for perforated ulcer, diverticulum, wound, injury or rupture (single or multiple perforations); without colostomy)

from 14.28 work RVUs to 16.03 work RVUs.

We agree with the increase in work RVUs for code 44604 but note that there are several rank-order anomalies currently in this family of codes that would be exacerbated by an across-the-board increase in work RVUs. Therefore, we propose to correct the rank-order anomalies as follows:

We propose 16.03 work RVUs for 44602

(Suture of small intestine (enterorrhaphy) for perforated ulcer, diverticulum, wound, injury or rupture; single perforation).

The work RVUs for code 44602 are identical to the work RVUs for code 44604 because they describe the same procedure except code 44604 is for the large intestine.

We propose work RVUs of 19.53 for code 44605

(Suture of large intestine (colorrhaphy) for perforated ulcer, diverticulum, wound, injury or rupture (single or multiple perforations); with colostomy).

The work RVUs for code 44605 are identical to the work RVUs for code 44604 except that code 44605 includes creating a colostomy with the attendant increase in postoperative wound care. The intraservice work of creating a colostomy is captured by subtracting the work RVUs for code 44140 from code 44143, which leaves 1.99 RVUs. In addition, there is one extra postoperative visit required for code 44605 that we believe is equivalent to code 99233 that has 1.51. work RVUs. Therefore, we added 1.99 and 1.51 work RVUs to the work RVUs for code 44604 to arrive at 19.53 work RVUs for code 44605.

We propose 18.66 work RVUs for code 44603

(Suture of small intestine (enterorrhaphy) for perforated ulcer, diverticulum, wound, injury or rupture; multiple perforations).

The additional work required for code 44603 as compared to code 44602 is similar to the additional work required for code 44605

as compared to code 44604 except, since there is no actual colostomy, the additional postoperative visit is comparable to code 99231 with 0.64 work RVUs. Therefore, we added work RVUs of 1.99 and 0.64 to the work RVUs of code 44602 to arrive at 18.66 work RVUs for code 44603.

The current work RVUs for codes 44640

(Closure of intestinal cutaneous fistula);

44650

(Closure of enteroenteric or enterocolic fistula);

44660

(Closure of enterovesical fistula; without intestinal or bladder resection);

and 44661

(Closure of enterovesical fistula; with bowel and/or bladder resection)

are rank-order anomalies as they are undervalued compared to code 44604. However, relativity among codes 44640, 44650, 44660, and 44661 is appropriate. To correct the anomalies, we compared codes 44650 to 50525

(Closure of nephrovisceral fistula (eg renocolic) including visceral repair; abdominal approach),

which involves similar intraoperative and postoperative work. The intraoperative work for code 50525 is greater than that of code 44650 because code 50525 involves visceral repair but the postoperative work for code 44650 is greater than the postoperative work for code 50525 because the fistula is enteroenteric or enterocolic as opposed to renovisceral (that is, renocolic). Therefore, we propose to assign 22.27 work RVUs to code 44650 and, to keep the current relativity with the other codes, we propose 21.65 work RVUs for code 44640, 21.36 work RVUs for code 44660, and 24.81 work RVUs for code 44661. We propose to accept the RUC recommendations for the remaining codes (44615, 44620, 44625, 44626, 44680, 44700, and 44850).

Family 8 Anus/Rectum—Hemorrhoids/Fistula

The RUC extrapolated a 14 percent decrease in work RVUs to all codes in this family based upon a decrease in work RVUs for the fully surveyed code 46262,

Hemorrhoidectomy, internal and external, complex or extensive; with fistulectomy, with or without fissurectomy.

We agree with the RUC recommendation for the surveyed code, but disagree with the extrapolation to the anal fistula repair codes and the anal abscess treatment codes. The surveyed intraoperative time for code 46262 is not consistent with the surveyed intraoperative times for many of the other codes in the family. Moreover, the work RVUs for many of the codes subject to the minisurveys are significantly less than for code 46262 and are not comparable. Therefore, we propose to maintain the current RVUs for codes 46270, 46275, 46280, 46288, 45000, 45020, 45100, 45108, 46040, 46045, and 46060. We agree with the RUC recommendations and propose to decrease the work RVUs for other codes in this family of codes (46250, 46255, 46257, 46258, 46260, 46261, 46262, 46934, 46936, 46945, and 46946).

Family 14B Abdomen, Peritoneum, Omentum

The RUC recommended an increase for the fully-surveyed code 49020,

(Drainage of peritoneal abscess or localized peritonitis, exclusive of appendiceal abscess; open,)

from 16.79 work RVUs to 20.73 work RVUs, the 25th percentile of surveyed work RVUs, based on a comparison to code 61312

(Craniectomy or craniotomy for evacuation of hematoma, supratentorial; extradural or subdural).

We disagree and propose the surveyed median work RVUs of 22.84. We compared code 49020 to code 35151

(Direct repair of aneurysm, false aneurysm, or excision (partial or total) and graft insertion, with or without patch graft; for aneurysm, false aneurysm and associated occlusive disease, popliteal artery),

48000

(Placement of drains, peripancreatic, for acute pancreatitis),

and code 48140

(Pancreatectomy, distal subtotal, with our without splenectomy; without pancreaticojejunostomy).

Code 48000 involves sicker patients but the intraoperative time (120 minutes) and postoperative visits (10-day length of stay for code 48000 with two critical care visits versus an 11-day length of stay for code 49020 with one critical care visit) are similar, and code 48000 has RUC-recommended work RVUs of 28.07. Code 48140, with RUC-recommended work RVUs of 22.94, has a longer intraoperative time (150 minutes) with a shorter length of stay (9 days with one critical care visit) and involves less sick patients. Code 35151, with RUC-recommended work RVUs of 22.64, involves patients not nearly as ill as patients for whom code 49020 is reported, has a surveyed intraoperative time of 150 minutes, and a 5-day length of stay with no critical care visits. Therefore, we propose the median surveyed work RVUs of 22.84 for code 49020. Since the current relativity within this family is correct, we propose to extrapolate this increase of 36 percent to the other codes in this family and value the work as follows: 49040 (13.52), 49060 (15.86), and 49085 (12.14).

Comment:

The American Society of Colon and Rectal Surgeons collaborated with the ACS and submitted 12 codes for review that they believe to be undervalued. They also expressed support for the methodology proposed by ACS to value services. The specific codes referenced were: 44130, 44144, 44147, 44151, 44156, 44394, 45111, 45113, 45337, 45339, 45910, and 46258.

RUC Recommendation:

The RUC recommended increasing the work RVUs for the following codes: 44130 (14.49), 45113 (30.58), and 45910 (2.80) to retain current rank-order and relativity within the grouping of services. However, for code 46258, the RUC recommended decreasing the work RVUs to 5.73 to retain the current rank-order and relativity within these services.

For codes 44147, 44394, 45111, 45337, 45339, 44144, 44151, and 44156, the RUC did not receive compelling evidence to suggest an increase was needed in the work RVUs; therefore, the RUC recommended that the current work RVUs for these codes be maintained.

HCFA Proposal:

We propose to accept all but one of the RUC recommendations for the surgical codes submitted by the American Society of Colon and Rectal Surgeons. For code 44147,

Colectomy, partial; abdominal and transanal approach,

we are proposing to increase the work RVUs by 14 percent to 20.71. This is similar to the increase applied to ACS family 6 and will prevent a rank-order anomaly.

Comment:

The American Academy of Otolaryngology-Head and Neck Surgery submitted codes, on behalf of the American Otological Society and the American Academy of Facial Plastic and Reconstructive Surgery, that they believe to be undervalued, along with suggested new work RVUs for each service. However, subsequent to the submission of their comments, the specialty society chose not to pursue revaluing of the following codes: (69450, 69436, 69440, 69631, 69205, 69801, 69633, 69501, 69632, 69905, 69666, 69650, 69806, 69667, 69720, 69641, 69550, 69636, 69637, 69643, 69140, 69505, 69635, 69502, 69645, 69511, 69601, 69602, 69642, 69603, 69644, 69910, 69660, 69604, 69646, 69662, 69661, 69930, 69145, 69676, 69310, 69620, 69805, 69670, 69700, 69802, 69320, 69530, 69820, 68711, 69840, 69540, 69421, 69552, 69150, 69915, 69605, 69300, 69000, 69005, 69020, 69711, 69100, 69105, 69110, 69120, 69140, 69145, 691500, 69155, 69200, 69205, 69210, 69220, 69222, 69300, 69310, 69320, 69400, 69401, 69405, 69410, 69420, 69421, 69424, 69433, 69436, 69535, 69554, 69610, 69725, 69740, 69745, 69950, 69955, 69960, 69970).

RUC Recommendation:

For codes 69990, 11642, 13131, and 13132, the RUC recommends no change to the current RVUs for these services, as compelling evidence was not provided to demonstrate the need for an increase.

HCFA Proposal:

We have reviewed and propose to accept all of the RUC recommendations for the surgical codes submitted by the American Academy of Otolaryngology-Head and Neck Surgery.

3. Thoracic Surgery

Comment:

In their comments, the Society of Thoracic Surgeons (STS) indicated that there have been major changes in the practice of thoracic surgery since the initial development of the physician fee schedule. These major changes in surgical techniques, along with changes in the typical patient, have had an impact on physician work. Time and intensity of a number of procedures, including the reference procedures used by STS, have been affected.

The STS grouped codes into three categories: general thoracic surgery, adult cardiac surgery, and congenital thoracic surgery. These three categories were grouped into 23 families of codes. Each family had an anchor code that received a full RUC survey. Each of the remaining codes in a family received a minisurvey. The minisurvey collected information on time and the number of postoperative visits. The minisurvey also asked respondents to estimate work RVUs for the procedure based on the reference service for the family of codes.

The RUC had a number of concerns with the STS approach. They are as follows: (1) The RUC concluded that STS inappropriately had the same survey respondents review and estimate both misvalued services and reference services. (2) In many instances, the respondents valued the code under review relative to their perception of what the reference code value should be, not the current value of the reference code. (3) The STS also used too many minisurveys and too few full surveys. (4) Within a family of codes, the STS inappropriately mixed codes with different global periods.

To overcome these methodological problems, the RUC first reviewed the reference service that was used for each family, and the resulting value was compared to the codes in each family. For the adult cardiac surgery codes, the RUC developed a building-block methodology to validate the survey results. For the congenital thoracic codes, previous RUC reviews of the codes were used to determine how the work has changed since the last 5-year review. In addition, for the pediatric thoracic codes, the specialty's society's presenter offered additional information demonstrating that the patient population has changed, (for example, more neonates) leading to a higher intensity of work.

Additionally, The STS subsequently chose not to pursue review of code 33207 under the 5-year review.

RUC Recommendations:

The RUC reviewed 89 thoracic surgery codes. Of this total, the RUC recommended increases for 44 codes, no changes for 43 codes, and decreases for 2 codes. The recommendations by family are as follows:

Family 1:

The RUC generally found that the STS had not furnished compelling evidence or that the STS inappropriately compared codes with a zero global period to codes with a 90-day global period. The RUC recommended no increase in work RVUs for codes 32000, 32005, 32020, 32035, 32225, 32602, 32651, and 32652. The RUC recommended increases in work RVUs for code 32220 (24.00) and code 32320 (24.00), based on the median surveyed work RVUs which would place these codes in proper rank order.

Family 2:

The RUC recommended increases for code 32440 (25.00) based on the median survey value, and code 32480 (23.75) based on the value of 43415. The RUC also recommended increases in work RVUs for codes 32100 (15.24) and 32110 (23.00) based on a comparison to code 58150. These values place all these codes in proper rank order.

Family 3:

The RUC recommended increases in codes 32482 (25.00) and 32500 (22.00), based on the STS surveyed median work RVUs for each code, which would create the proper rank order within the family of codes.

Family 4:

The RUC recommended no increase for code 32655 because the STS had not furnished compelling evidence for an increase in work. The RUC recommended increases for codes 31600 (7.18) and 32500 (22.00) based on survey data, a sicker patient population, and, in the case of 31600, comparison to 35474.

Family 5:

The RUC recommended increases for codes 38746 (4.89) based on the work RVU for 38747, but recommended no increases for codes 39010, 39220 or 39400 due to lack of compelling evidence or inappropriate comparisons to codes with 90-day global periods.

Family 6:

The RUC agreed with the STS analysis of work for codes 43107 (40.00) and 43112 (43.50) and stated that using the survey median for each code correctly rank ordered these codes in the family of esophagectomy codes.

Family 7:

The RUC recommended an increase for code 43117 (40.00) after comparing it to the reference service code 43361 which had similar data. The RUC also recommended an increase for code 43122 (40.00) based on the survey median of 40.00 work RVUs which correctly rank ordered this code in the family of esophagectomy codes.

Family 8:

The RUC recommended no increase for codes 31625 or 31645 because the STS did not furnish compelling evidence for an increase in work.

Family 9:

The RUC recommended increases for the following codes: 33400 (28.50), 33405 (35.00), 33406 (37.50), 33411 (36.25), 33412 (42.00), and 33413 (43.50), based on a building-block approach that used code 33405 as the anchor code for this family.

Family 10:

The RUC recommended increases for the following codes: 33426 (33.00), 33427 (40.00), 33430 (33.50), and 33475 (33.00), based on a building-block approach that used code 33427 as the anchor code for this family. The RUC recommended no increases for codes 33425 or 33468 because the building-block approach did not support the STS's requested increase.

Family 11:

The RUC recommended increases for the following codes: 33510 (29.00), 33511 (30.00), 33512 (31.80), and 33513 (32.00), based on a building-block approach that used code 33512 as the anchor code for the family. The RUC recommended decreases for codes 33514 (32.75) and 33516 (35.00). These were the values recommended by the STS and validated through the building-block approach.

Family 12:

The RUC recommended no increases for the following add-on codes: 33517, 33518, 33519, 33521, 33522, 33523, and 33530, because it believes that they were inappropriately surveyed as 90-day global procedure codes and the results were not reliable.

Family 13:

The RUC recommended increases in work RVUs for the following codes: 33533 (30.00), 33534 (32.20), 33535 (34.50), and 33536 (37.50), based on a building-block approach that used code 33533 as the anchor code for the family of codes. The RUC recommended no increase for code 33530 because it is an add-on code and was inappropriately surveyed as a 90-day global surgical procedure.

Family 14:

The RUC recommended increases in work RVUs in the following codes: 33860 (38.00), 33861 (42.00), 33863 (45.00), and 33870 (44.00) based on a building-block approach that used code 33860 as the anchor code for the family. The RUC recommended no increase for code 33945 because the building-block approach did not

support the higher value requested by the STS.

Family 15:

The RUC recommended no increases in work RVUs for the following codes: 33750, 33820, and 33840, due to lack of compelling evidence to support an increase.

Family 16:

The RUC recommended an increase in code 33660 (30.00) based on intraservice work RVUs for 33401 and pre- and postservice work RVUs for 33641. The RUC recommended no increase in code 33641 as it did not find any compelling evidence to warrant a change in the work RVUs.

Family 17:

The RUC recommended no increase in work RVUs for code 33415, because it did not believe that the typical patient for this procedure has changed, and the minisurvey did not provide compelling evidence to justify a change in the work RVUs. However, the RUC recommended an increase in work RVUs in code 33681 (30.61), because the intraservice intensity of 33681 is more complex than it was 5 years ago.

Family 18:

The RUC recommended increases in the following codes: 33615 (34.00), 33670 (35.00), and 33730 (34.25) based on a comparison to code 33412.

Family 19:

The RUC recommended increases in work RVUs for the following codes: 33611 (34.00), 33612 (35.00), 33694 (34.00) and 33697 (36.00). The RUC compared the intraservice time of code 33611 to the family anchor code of 33694 and recommended 34.00 work RVUs to maintain proper rank order in the family. The RUC compared code 33612 to code 33611 and agreed code 33612 was equivalent to 33611 plus 1 additional work RVU. The RUC compared code 33694 to 33412 and concluded that all measures of physician work were greater for 33694. The RUC compared code 33697 to 33694 and recommended 36.00 work RVUs to maintain rank order. The RUC recommended no increase for 33767 because there was no compelling evidence for a change in the work RVUs.

Family 20:

The RUC recommended an increase in code 33617 (37.00), after comparing it to code 33412 and noting that 33617 has greater intraservice time and higher intensity ranking than code 33412.

Family 21:

The RUC recommended an increase in code 33619 (45.00) after comparing it to codes 48150 and 62530.

Family 22:

The RUC recommended an increase in code 33506 (35.50) to preserve proper rank order within this family. The RUC recommended an increase in code 33770 (37.00) after finding that the work of this code is more than that of the comparison code 33697. The RUC recommended an increase in code 33778 (40.00), after comparing it to 33870, and 33412 which are less intense procedures. The RUC recommended an increase in code 33780 (41.75), based on a comparison to 33778. 33780 involves more work and warrants an additional 1.75 RVUs due to the additional 35 minutes of intraservice time.

Family 23:

The RUC recommended an increase in code 33786 (39.00) after comparing it to 33412, which has less time and intensity. Given the limited specialty survey data, the RUC believed that the recommended increase in code 33919 to 40.00 work RVUs was warranted, but that the survey did not support a value higher than the median survey value.

Based on information supplied to the RUC, the RUC did not recommend a change in RVUs for codes 32520, 33917, 31622, and 32657. For codes 32095, 33410 and 32491, the RUC indicated that it had recently reviewed these codes, and thus it recommended no change. The RUC recommended that codes 33875, 33877, 43107, and 43112 be referred to the CPT Editorial Panel.

HCFA Proposal:

We validated the RUC recommendations by comparing the thoracic surgery codes to vascular surgery and general surgery codes and propose to use the RUC-recommended work RVUs for the thoracic codes based on our own analysis. The following is an example of our review of the thoracic surgery codes. We compared code 32440 (

Removal of lung, total pneumonectomy

) (25.00 work RVUs) with a preservice time of 90 minutes, intraservice time of 160 minutes, one intensive care unit visit, six hospital visits, and three office visits with the following surgical codes in other surgical specialties: code 34151 (

Embolectomy or thrombectomy, with or without catheter; renal, celiac, mesentery, aortoiliac artery, by abdominal incision

) (25.00 work RVUs) with a preservice time of 75 minutes, intraservice time of 150 minutes, seven hospital visits, and three office visits and code 44150 (

Colectomy, total, abdominal, without proctectomy; with ileostomy or ileoproctostomy

) (23.95 work RVUs) with a preservice time of 63 minutes, intraservice time of 200 minutes, eight hospital visits, and three office visits. A review of these codes demonstrates the similarity in preservice time and intraservice time and the proposed RVUs maintains relativity across surgical specialties.

4. Orthopedic Surgery

Comment:

The American Academy of Orthopaedic Surgeons forwarded 42 codes for review. It indicated that these codes were undervalued when compared to their respective reference codes.

RUC Recommendation:

The RUC recommended increasing the work RVUs for the following codes: 29883 (11.05) because this service consists of two procedures; 29889 (16.00) based on increase in post and intraservice work; 29450 (2.08) based on the increased intraservice time for manipulating the foot of the patient; code 28299 (9.18) which is of value equal to the reference code, with the understanding that the code be sent to CPT Editorial Panel to better define the code; code 28705 (18.80), which more accurately reflects the work of the two distinct services of this procedure (ankle fusion and triple arthrodesis); code 23472 (21.10) to correct a rank-order anomaly; code 26562 (15.00) to correct a rank-order anomaly; code 20245 (8.50) to correct a rank-order anomaly; code 27075 (35.00) noting that this is a major operation and there is increased intraservice time with respect to the reference code; code 27077 (40.00) noting that this a major operation and there is increased intraservice time with respect to the reference code; 27284 (23.45) because this is the value for code 27227 that has identical pre-, intra-, and postservice times; code 27286 (23.45) to avoid creating a rank-order anomaly due to the recommended work RVUs increase of code 27284; code 27822 (11.00) to correct an existing rank-order anomaly; code 27823 (13.00) to avoid creating a rank-order anomaly caused by increasing code 27822; code 28445 (15.62) to correct a rank-order anomaly and appropriately reflect the work involved; code 27724 (18.20) to reflect the work for obtaining a graft that was not included in the last 5-year review.

The RUC believed that the commenter provided no compelling evidence to revise the work RVUs for codes 27280, 27282, 23585, 23615, 23630, 23680, 24545, 27216, 27217, 27218, 27226, 27236, 27513, 27536, 27828, 23485, 24435, 27472, 28322, and 28420. Therefore, the RUC recommended the current work RVUs be maintained for these codes.

The RUC referred the following codes to the CPT Editorial Panel for clarification: 23076, 24076, 25076, 27048, 27328, 27619, and 20205, because these codes are being reported incorrectly.

HCFA Proposal:

We propose to accept all but one of the of the RUC recommendations for the orthopedic surgery codes. For code 20245, (

Biopsy, bone, excisional; deep (eg, humerus, ischium, femur

), the RUC recommended an increase from 3.95 work RVUs to 8.5 work RVUs and compared code 20245 to codes 27635 (

Excision or curettage of bone cyst or benign tumor, tibia or fibula

), and 27607 (

Incision (eg, osteomyelitis or bone abscess), leg or ankle

) (work RVUs of 7.78 and 7.97, respectively), because it believed the work required for code 20245 was similar to the work required for these codes. The survey for code 20245 compared the code to code 27635. The intraservice times were similar (90 versus 85 minutes) and the amount of postservice was similar (169 versus 163 minutes). However, the survey median work RVUs were 13 and the 25th percentile RVUs were 8.5. The RUC recommended the 25th percentile RVUs because the RVUs were reasonably close to the RVUs for code 27635. We agree that the current work RVUs are a rank-order anomaly with code 20240 (

Biopsy, bone, excisional; superficial (eg, ilium, sternum, spinous process, ribs, trochanter or femur

)); however, we disagree with the RUC recommendation. The intraservice work of a deep excisional bone biopsy is similar to the work of excising a bone cyst or benign tumor from the tibia and fibula (code 27635). This is reflected in the similarity in their pre-, intra-, and postservice times. Moreover, the vignette used for code 20245 was atypical in that it involved an ischial lesion, whereas the code is also to be reported for lesions of the humerus and femur. Lesions of the humerus and femur require less dissection and would be more comparable to lesions of the tibia and fibula. Moreover, code 27635 requires complete removal of a known lesion, whereas code 20245 is only an excisional biopsy. Additionally, we are concerned about the spread of work RVUs in the work survey (25th percentile was 8.5 RVUs and 50th percentile was 13.0 work RVUs) and lack of consistency with the time data from the survey. We do not believe there is compelling evidence that the work of code 20245 is greater than the work of code 27635 and are therefore proposing to assign 7.78 work RVUs to code 20245, which is identical to work RVUs for the reference service code 27635.

5. Ophthalmology

Comment:

The American Academy of Ophthalmology submitted comments requesting nine codes be reviewed, including one code for evaluation of the global period and not the work RVU. The specialty society subsequently chose not to pursue review of codes 66170, 66172, and 67108.

RUC Recommendation:

The RUC agreed with the request from the specialty society to change the global period from 90 days to 10 days for code 65855 (

Laser surgery of eye

) and also reduced the work RVUs to 3.85 to account for this reduction in the global period. The RUC noted that code 67218 includes two procedures, and the specialty society indicated that this was not reflected in the original valuation. To correct this error, a building-block approach was used to arrive at new RVUs more reflective of the work of both procedures. The RUC recommended work RVUs of 18.53 for this service. For code 92018, the RUC acknowledged that the preservice work of this service was greater than the standard office procedure because of the need for anesthesia. While concerned about the reliability of the data provided, the RUC recommended that the work RVUs be increased to 2.50, as it suggested during the first 5-year review, with the understanding that the code would be sent to the CPT Editorial Panel for clarification.

For codes 66180, 66986, 67028, and 67904, the RUC believed that the commenters provided no compelling evidence to justify an increase in the work RVUs; therefore, the RUC recommended maintaining the current value for this code.

HCFA Proposal:

We have reviewed and propose to accept all of the RUC recommendations for the ophthalmology codes.

6. Urology

Comment:

The American Urological Association presented four codes for review: 50230, 51595, 51596, and 38780. They believed that the work RVUs for these codes do not account for all the in-hospital and office-based postoperative care.

RUC Recommendation:

The RUC questioned the arguments for an increase in RVUs, noting that there was no compelling evidence presented for recommending an increase for three of these codes (51595, 51596 and 38780). However, the RUC noted that the code descriptor for code 50230 includes the term “and/or vena caval thrombectomy” which impacts the work RVU. The RUC agreed to refer this code back to the CPT Editorial Panel to separate these two distinct services so each may be reported and valued appropriately.

HCFA Proposal:

We have reviewed and propose to accept all of the RUC recommendations for the urology codes.

7. Obstetrics/Gynecology

a. Specialty Comments

Comment:

The American College of Obstetrics and Gynecology (ACOG) referenced 35 codes in their written comments submitted to us. The specialty society chose not to pursue the review of work RVUs for code 57555, as well as the work RVUs for codes 59150 and 59151.

RUC recommendation:

The RUC recommended increases in the RVUs for the following codes: 38572 (16.59) that would align the code relative to the work of other laparoscopic codes; 56515 (2.76), which was not the value requested by the specialty group but was the value assigned to code 46924, which has comparable work and intraservice time; 56740 (4.57) based on a modified building-block approach, which was similar to ACOG's approach; 57100 (1.20) as presented by the specialty society; 58152 (20.60) in recognition that the current work RVUs are less than the RVUs for code 58150 performed alone even though 58152 combines the work of codes 58150 and 58840; 58260 (12.98) to reflect work of additional office visits included in the procedure; 58262 (14.77) to accurately reflect the work of its component procedures; 58263 (16.06), 58275 (15.76), 58270 (14.26) and 58280 (17.01) to maintain relativity within family of hysterectomy codes; 58267 (17.04) because the procedure is currently undervalued since it encompasses three separate components; 58285 (22.26), which was lower than requested by the specialty group, but which the RUC believed was more reflective of the work for the procedure; 58600 (5.60) based on similarity of this procedure to code 58670; 58605 (5.00) to reflect the slightly lower pre-, intra-, and post-times for this code as compared to 58670; 58611 (1.45) to appropriately reflect the increase in preservice work; 58700 (12.05) reflecting the higher technical skill associated with this procedure (removing only fallopian tube versus ovary and fallopian tube); 58740 (14.00) to reflect increase in intra-service time and postoperative work; 58825 (10.98) which aligns the work value with other codes with similar work; 58920 (11.36) to correct a rank-order anomaly; 58950 (16.93) which combines both codes 58720 and 49255 and applies the multiple procedure rule; 58951 (22.38) based on the similarity of work to 58285 which has the same

recommended value; 59812 (4.01) based on the similarity of work to code 59820; 59870 (6.01) based on increased physician work and postoperative time.

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