ASA Opposes CMS Decision to Lower Values for Interlaminar Epidurals in 2014 Final Rule

As part of the CY 2014 Medicare Physician Payment Rule, CMS lowered the values for important Interlaminar Epidural procedures.  These draconian cuts were not part of the proposed rule so no comment period was provided to stakeholders such as the ASA prior to the release of the final rule.  ASA is strongly opposed to the reduction in values for these codes and opposed to the implementation of such significant reductions without a public comment period. 

Code 62311 (single shot lumbar/sacral) was flagged as potentially misvalued per the Centers for Medicare and Medicaid Services (CMS) High Expenditure Procedural codes screen in the proposed rule for the 2012 fee schedule (7/19/2011 Federal Register).  When one code in a family is so flagged, the value of all codes in the family is called into review.  Subsequently, code 62311 and 62310, 62318 and 62319 were subject to the AMA/Specialty Society RVS Update Committee (RUC) survey process in the summer of 2012.  ASA and other societies whose members perform these services conducted the surveys and presented the results to the RUC that fall.    

As a result of the process, the RUC recommended maintaining the current work value for three out of these four of these codes. CMS disagreed and has significantly lowered the work relative value units (RVUs) for all of the codes.

 





 


Additionally, the Practice Expense RVUs were also revised by CMS as the existing inputs were from the original valuation and in some instances, inconsistent with current practice.

These are high-volume codes so the impact is important for physicians providing important pain care services to Medicare beneficiaries.  The new values will become effective for services provided on/after January 1, 2014.  Per standard process, the values will be interim for 2014 and finalized in 2015 after stakeholders have had the belated opportunity to comment on this CMS decision.  

ASA has begun a thorough analysis of CMS's process for determining the new values and will be communicating with CMS regarding its disagreement with the decision. CMS will be urged to reconsider the severe, unjustified cuts. ASA has already communicated with other organization representing physicians who perform these procedures and is exploring the full range of other options available to address this matter.