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- Apr 16, 2004
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https://www.astro.org/ASTRO/media/ASTRO/News and Publications/PDFs/MPFSQPPProposedRuleCommentLetter.pdf
A few points:
1. CMS has used a third-party contractor (StrategyGen) to estimate the price of various pieces of radiation equipment. This has led to highly dubious estimates as to the cost of an SBRT/SRS platform ($900k!), HDR afterloading units, IMRT treatment planning systems, and dedicated brachy vaults.
2. CMS has bundled E/M codes for various internal medicine specialties but Rad Onc seems to have been included inadvertently. Most of our visits are level 4/5 in complexity.
3. CMS is still considering the Rad Onc specific APM recommended by ASTRO - this needs to be approved as other APMs clearly do not apply to our specialty.
A few points:
1. CMS has used a third-party contractor (StrategyGen) to estimate the price of various pieces of radiation equipment. This has led to highly dubious estimates as to the cost of an SBRT/SRS platform ($900k!), HDR afterloading units, IMRT treatment planning systems, and dedicated brachy vaults.
2. CMS has bundled E/M codes for various internal medicine specialties but Rad Onc seems to have been included inadvertently. Most of our visits are level 4/5 in complexity.
3. CMS is still considering the Rad Onc specific APM recommended by ASTRO - this needs to be approved as other APMs clearly do not apply to our specialty.