This is in regard to the 2020 Medicare Physician Fee Schedule Proposed Rule, released by the Centers of Medicare and Medicaid Services (CMS) on July 29, 2019.  Specifically, the proposed rule proposed a recommended work Relative Value Unit (RVU) of 9.03 of CPT code 27279, Arthrodesis, sacroiliac joint, percutaneous or minimally invasive (indirect visualization), with image guidance, includes obtaining bone graft when performed, and placement of transfixing device.  In the proposed rule, CMS indicated they were seeking comment on whether to adopt a work RVU of 20.00 which is the work RVU for CPT code 27280, Arthrodesis, open, sacroiliac joint, including obtaining bone graft, including instrumentation, when performed to achieve site-of-service parity and eliminate incentives for facilities to use a higher valued procedure.

CPT 27279 for MIS SIJ Fusion was originally reviewed in 2014, prior to ISASS became a member of the AMA House of Delegates. Since then, ISASS has argued to CMS and the AMA Relative Value Updated Committee (RUC) that the 2014 value was and is inappropriate and inaccurately based on a flawed comparison to a discetemy procedure (CPT code 62287, Decompression procedure, percutaneous, of nucleus pulposus of intervertebral disc, any method utilizing needle based technique to remove disc material under fluoroscopic imaging or other form of indirect visualization, with discography and/or epidural injection(s) at the treated level(s), when performed, single or multiple levels, lumbar). ISASS presented CMS with results from a Rasch Analysis and other quality data, which led CMS to formally list 27279 as potentially misvalued in consecutive Medicare Physician Fee Schedule Final Rules in 2016 and 2017 and requested the AMA RUC to re-evaluate 27279 as potentially misvalued. The AMA RUC reviewed the request from societies, including ISASS, and provided a recommendation to CMS to maintain the 9.03 value.  ISASS met with CMS & ultimately the White House Office of Management and Budget (OMB) requesting parity for 27279 with 27280. As a result of the continual misvaluation of 27279, subsequent emerging tech like Coflex (CPT Code 22867, Insertion of interlaminar/interspinous process stabilization/distraction device, without fusion, including image guidance when performed, with open decompression, lumbar; single level) have been similarly undervalued.

In response to the proposed rule and request for comments, ISASS is asking its U.S. members to submit comments requesting parity for 27279 with 27280.  ISASS believes if CMS adopts this proposal, it will provide better quality care for patients and millions of dollars of savings to CMS if patients who are currently being treated in inpatient settings due to the financial incentive of using 27280 shift to the outpatient or Ambulatory Surgical Center (ASC) setting. Correcting 27279 RVU will also provide an appropriate ASC Spine Code benchmark comparator for emerging tech codes moving forward.

Please help CMS do what is right not what is easy by submitting your individual responses. For a sample letter that can downloaded with your own name and then submitted via the link, please download this DRAFT ISASS Member Comment letter to CMS 8-19 and tailor to your experience and practice. Then submit the letter to the CMS website by clicking here.

Thank you for your advocacy for our profession.

Sincerely,

Morgan Lorio, MD, FACS

Chair, ISASS Coding and Reimbursement Task Force