On Tuesday, Aug. 9, the AASM sent a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining concerns regarding the 2012 Physician Fee Schedule Proposed Rule.  As discussed in the July 28 Coding Corner article, the Proposed Rule includes a number of changes that will significantly affect sleep physicians.  The AASM comment letter focuses on the following four issues:

  • Decrease in RVUs for Home Sleep Testing: The Proposed Rule suggests that the practice expense (PE) relative value units (RVUs) for codes 95800 and 95801 will be cut significantly.  The proposed cuts are close to 27 percent and 18 percent.  Following conversations with CMS and American Medical Association (AMA) staff, it is the understanding of the AASM that these cuts are a result of CMS using an inappropriate specialty blend to calculate the new practice expense figures.  The AASM comment letter outlines these concerns and suggests an alternative calculation that would result in a far less drastic cut.
  • Decrease in RVUs for code 95810: The Proposed Rule indicates that the PE RVUs for code 95810 may decrease by 6 percent.  This change would result in the total RVUs for code 95808 being higher than the total RVUs for code 95810, which is inappropriate because code 95810 reflects a service that requires more labor and equipment than code 95808.  The AASM comment letter requests that CMS increase the PE RVUs for code 95810 so that the total RVUs for 95810 are greater than the total RVUs for code 95808.
  • Changes to the Conversion Factor: The Proposed Rule indicates that the conversion factor is expected to be cut by 29.5 percent in 2012.  This proposed cut is mandated by law as a result of the sustainable growth rate (SGR) formula.  The AASM comment letter stresses the catastrophic strain that such a cut would put on AASM membership and urges CMS to push for a long-term solution.
  • Inclusion of the Sleep Apnea Measures Group in the 2012 PQRS Program: The Proposed Rule reflects inclusion of a sleep apnea measure group in the 2012 Physician Quality Reporting System (PQRS) Program.  The AASM comment letter thanks CMS for including sleep measures in this program.

The AASM will continue to update members regarding further communication with CMS.  Members also are encouraged to provide CMS with their own comments on the 2012 Physician Fee Schedule Proposed Rule. Comments to CMS are due by Aug. 30 using the contact information found on the first page of the Proposed Rule.

Coding Corner articles are archived on the Coding Page of the AASM website for future reference.