AUA’S COMMENT

FINAL RULE PROVISION

Supported the CMS proposed, and RUC recommended work RVUs for CPT code 52284 - Cystourethroscopy, with mechanical dilation and urethral therapeutic drug delivery for urethral stricture or stenosis, including fluoroscopy, when performed.

CMS finalized work RVU of 3.10. Code will be available for use January 1, 2024.

Supported the CMS proposed which were RUC recom- mended to increase the work RVUs for neurostimulator services CPT codes 64590 - Insertion or replacement of peripheral, sacral, or gastric neurostimulator pulse gen- erator or receiver, requiring pocket creation and con- nection between electrode array and pulse generator or receiver and 64595 -revision or removal of peripher- al, sacral, or gastric neurostimulator pulse generator or receiver, with detachable connection to electrode array. Supported revising equipment time for 64590 to com- port with the service time.

CMS finalized work RVUs of 5.10 for CPT 64590 and

3.79 for code 64595. Additionally, the agency corrected the equipment times for code 64590.

Commented on the lack of updates to conversion factor, recognizing that CMS cannot update the conver- sion factor without Congressional intervention.

CMS did not address any specific comments in the final rule but was appreciative of comments from all stake- holders.

Commented in support of delay in using revised Medi- care Economic (MEI) Index data until the AMA Physi- cian Practice Information Survey (PPIS) is complete.

CMS agreed and will not use updated MEI inputs for rate setting in 2024. The AMA is waiting for the PPIS to be completed to determine how it will use that data in future rulemaking.

AUA supported the continued collaboration between the RUC and CMS and supports the processes being used.

CMS thanked all for the comments and will consider comments in future rulemaking should there ever be a need to change the valuation process.

Supported the use of medical decision or time as the deciding factor when determining which clinician pro- vided the substantive portion of a split/shared service. The substantive portion is then used to determine which provider bills for the E/M service in the facility setting.

CMS finalized that time or medical decision making may be used to determine the substantive portion of an E/M service provided in the facility setting.

Supported telehealth policies of the Consolidated Appropriations Act (CCA) of 2023 including the allow- ing the beneficiaries home as an originating site, the payment for audio-only E/M until December 31, 2024

CMS finalized the policies as required by the CCA, 2023.

Supported the existing definition of virtual direct super- vision and urges CMS to allow direct supervision via virtual presence to be a permanent policy

Virtual supervision will be allowed until December 31, 2024.

Supported the creation of HCPCS code to report the services associated with providing a SDOH risk assess- ment. Asked for clarification as to billing frequency.

CMS finalized payment and frequency parameters for the new HCPCS code for SDOH risk assessment. The code may be billed once every six months per patient, per provider.

Commented in support of principal illness navigation (PIN) services, and requested clarification on definition of serious, high-risk condition.

Per the final rule “the definition of a serious, high-risk condition is dependent on clinical judgement.” Ex- amples include, and the list is not exhaustive per the agency cancer, chronic obstructive pulmonary disease, congestive heart failure, dementia, HIV/AIDS, severe mental illness, and substance use disorder (SUD).

Submitted comments on complex drug administration coding, advising CMS to refer the codes to CPT Editori- al Panel for revision.

CMS received comments on this issue and will take comments into consideration should any policy chang- es be forthcoming.