The Society Comments on the 2009 Physician Fee Schedule Final Rule

On December 22, 2008, the Heart Rhythm Society submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the 2009 Medicare Physician Fee Schedule final rule. In the Society’s comments  (PDF,1.33MB)  to CMS, three areas of concern related to the new cardiac monitoring device codes were addressed:

• reimbursement for programming evaluation of a dual lead ICD system (93283)
• practice expense equipment cost for codes 93279 through 93292
• practice expense equipment cost for transtelephonic rhythm strip pacemaker evaluation (93293)

In its 2009 final rule, CMS reduced the work value assigned by the American Medical Association’s RVS Update Committee (RUC) for programming of a dual lead ICD to synchronize work RVU increments between a single lead, a dual lead and a multiple lead ICD system, assuming that the work between codes is linear.

The Society disagrees with this decision and has recommended that CMS support the value recommendation of the RUC.