In a letter submitted Feb. 10, 2020, Dr. Morgan Lorio, Chair of the ISASS Coding and Reimbursement Task Force, asked the Centers for Medicare and Medicaid Services (CMS) to review the Relative Value Units (RVUs) assigned to CPT 22867, Insertion of interlaminar/interspinous process stabilization/distraction device, without fusion, including image guidance when performed, with open decompression, lumbar; single level (Co-Flex) and identify the procedure as misvalued under the Medicare Physician Fee Schedule in the 2021 Medicare Physician Fee Schedule Proposed Rule.

ISASS argued that the recent Medicare valuations of 22867 was undervalued by CMS in 2015 when it was added to the Medicare Physician Fee Schedule as a result of a flawed process and flawed assumptions made in the review process.

The letter asks CMS to increase the RVUs for 22867 for the 2021 Medicare Physician Fee Schedule while also further reviewing the valuation process for future rulemaking. CMS officials acknowledged receipt of the request and indicated they would review it as part of their proposed rulemaking process. The 2021 Medicare Physician Fee Schedule Proposed Rule is expected to be released in July 2020.

Read Letter to CMS RE: CPT 22867