Re: CMS-1590-FC Medicare Program; Revisions to Payment Policies Under the Physician
Fee Schedule, DME Face to Face Encounters, Elimination of the Requirement for
Termination of Non-Random Prepayment Complex Medical Review and Other Revisions
to Part B for CY 2013
Dear Acting Administrator Tavenner:
The American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons
(CNS) appreciate the opportunity to provide comments regarding the above cited Medicare physician fee
schedule, published in the Federal Register on November 16, 2012. Specifically, we are requesting a
Refinement Panel for seven procedures and have outlined our rationale below
Cervicocerebral Angiography Codes
Cervicocerebral Angiography codes (36200, 36215, 36216, 36217, 36218, 75650, 75665, 75671, 75680,
75685, 75774) were captured in the screen that identifies code pairs reported together more than 75
percent of the time and CMS asserted that there is some duplication of work among the carotid
angiography codes when various carotid angiography services are provided together. Therefore, new
codes that bundle non-selective and selective arterial catheter placement and diagnostic imaging of the
aortic arch, carotid and vertebral arteries, were created for CPT 2013, CPT Codes 36221-36228. In the
Final Rule, CMS significantly reduced the RUC-passed values for seven of the eight new codes (see
chart below), keeping the RUC value only for CPT Code 36228. We strongly object to this action and
request that CMS convene a Refinement Panel to reconsider these values.
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Read full letter here
