As the American College of Radiology (ACR) submitted comment letters on the Centers for Medicare and Medicaid Services (CMS) proposed rules for 2014, there was much consternation swirling around the topic of potential cuts to the codes for image-guided breast biopsy. It is worth reviewing how code values are developed and at what point they become public.
The American Medical Association’s (AMA) Relative Value Update Committee (RUC) reviews codes created or modified by the CPT Editorial Panel. The RUC sends its recommendations for code values to CMS. CMS is the final arbiter and the code values are only made public when CMS has weighed in. In the majority of cases CMS accepts the RUC’s recommendations, but increasingly CMS will make changes to the values, often downward.
A new set of bundled codes for image-guided breast biopsy was created by the CPT Editorial Panel CMS’ request last year. Those codes were reviewed by the RUC and recommended values sent to CMS. CMS will publish the values for these codes with the Final Rule around Oct. 31, 2013. Until that happens the RUC’s recommended values are confidential. If we breach that confidentiality, ACR’s continued participation in the RUC process will be jeopardized.
If, when the codes are published we feel that the values do not accurately reflect the effort involved (or will cause access to these services to be denied to our patients) we will have the opportunity to appeal the values as they are considered interim for one year. Watch this space!