August 24, 2009
CMS Proposes to Cut Values for Pain Services – Submit Comments by Aug. 31
We want to make you
aware of an element in the Centers for Medicare and Medicaid Services
(CMS) proposed rule for the 2010 Physician Fee Schedule which will
affect your pain practice.
proposing to reduce the values for specific pain services, including
spinal pumps and stimulators. The RUC reviewed these codes in 2008,
and CMS implemented reduced values for these services effective Jan. 1,
2009. Now, CMS is proposing to reduce the values even further using a
suspect methodology, widely-rejected by other groups including ASA, AMA
and other pain societies.
Please take action against this harmful proposal by submitting a comment letter to CMS. Comment letters must be received by August 31, 2009—just 10 days from today. Please don’t delay in submitting your comments.
will address this issue in its comment letter to CMS, but is important
that the Agency hear from you—the physician—representing the patients
who need these services.
- Go to this link
- Complete your personal information. For “category,” make sure you scroll down to select “Physician.”
- Copy the sample letter provided at the end of this message.
- Paste the sample letter in the comment box on the CMS website.
- Click “Submit.”
- When you successfully submit comments, you will receive a confirmation
code. Please retain this information for your records as it will not
be emailed to you.
- Tell your
colleagues/partners/administrators/practice managers/students that we
need their help, too. Please encourage others to take this important
- Let ASA know that you’ve
done your part! To report that your comments have been sent, please
email Moriah Merkel in the ASA Washington Office at firstname.lastname@example.org
has changed the link and commenting procedure twice since the proposed
rule was released. If you have difficulty submitting comments, please
contact Moriah Merkel (email@example.com) or Sarah Byun (firstname.lastname@example.org) in the ASA Washington Office at 202-289-2222
- There is a 2,000 character limit on comments. Please keep this in mind if you choose to edit the sample message.
of submitting comments electronically, you may choose to mail written
comments to CMS. Please use the following address, and be sure to
allow sufficient time for mailed comments to be received by Aug. 31:
Centers for Medicare & Medicaid Services
Department of Health and Human Services
P.O. Box 8013
Baltimore, MD 21244-8013
Roger A. Moore, M.D.
RE: AMA RUC Review of Potentially Misvalued Codes – Site of Service Anomalies
am writing to express my grave concerns about CMS’ proposal to further
reduce the values of CPT codes associated with spinal pumps and
stimulators, CMS-1413-P. I strongly urge CMS to maintain the current
values, which were recommended by the RUC in 2008 and implemented by
CMS in 2009. Further reduction in these values would:
access to pain care because the proposed values would not cover the
cost of the resources required to provide the services
- Skew the fee schedule as the methodology used to arrive at these reduced values completely ignores relativity
- Limit the availability of pain services that have been established as safe and effective
the methodology CMS used to arrive at these values is so flawed that it
results in negative values for some of the services to which it was
applied. CMS itself acknowledges this weakness when it suggests
maintaining current values for those codes for which the methodology
results in negative values. It is essential that the Fee Schedule be
based on methodologies that are statistically valid and can be
consistently applied. This is clearly not the case in this instance.
I urge CMS to maintain the existing values for these codes for the 2010 Physician Fee Schedule.