In early June, the Centers for Medicare & Medicaid Services (CMS) issued a Notice of Proposed Rule Making (NPRM) in which it announced proposed changes to the work relative value units (RVUs) assigned to services that were evaluated as part of the 4th Five Year Review. CMS is required to review work RVUs at least every five years. This NPRM is focused on codes that were surveyed last summer as part of that review. ASA had one code in that review – a greater occipital nerve block. In this NPRM, CMS disagrees with the RUC recommendation for this service and in the letter, ASA is asking CMS to reconsider its position.
This is a different rule than the proposed rule on the 2012 Physician Fee Schedule which was recently published. The fee schedule rule is much broader than this one and ASA will submit comments on many of the issues in the fee schedule NPRM separately.
Click here to read the comment letter.