At least one of the big boys is lending a hand
Medtronic, Inc.
7000 Central Avenue NE
Minneapolis, MN 55432
www.medtronic.com
December 30, 2013
Ms. Marilyn Tavenner, Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1600-FC
Room 445-G, Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, DC 20210
Re: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY 2014
Dear Ms. Tavenner:
Medtronic is the world’s leading medical technology company, specializing in implantable and interventional therapies that alleviate pain and restore health. We work with health care providers to ensure patients have access to high quality care and effective, innovative medical technologies in appropriate care settings. Our Neuromodulation Division provides pain solutions for patients including intrathecal drug delivery and spinal cord stimulation therapies.
In this interest, we appreciate the opportunity to comment on the CY 2014 interim final RVUs for Interlaminar Epidural procedures (CPT codes 62310, 62311, 62318, 62319). In addition to use with epidural injections, CPT codes 62311 and 62319 are also used for intrathecal drug delivery trials. We are concerned that the significant reduction in payment for these procedures will limit access to these important treatments and compromise the viability of many US pain practices.
For CY 2014, CMS received AMA RUC recommendations for the work RVUs and direct practice expense inputs for the Interlaminar Epidural procedure codes. CMS significantly reduced the AMA RUC work recommendations for all these codes and accepted the direct practice expense inputs. As the table below indicates, CMS did not accept any of the RUC recommended work RVUs and decreased all the work RVUs, resulting in percent change decreases ranging from -24.7% for CPT code 62319 to -61.9% for CPT code 62310.
CPT Code
CY 2013
Work RVUs
AMA RUC Recommended Work RVUs
CY 2014
Work RVUs
Percent Change in Work RVUs
62310
1.98
1.68
1.18
-61.9
62311
1.54
1.54
1.17
-31.6
62318
2.04
2.04
1.54
-32.5
62319
1.87
1.87
1.50
-24.7