On September 23, ISASS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on their proposed rule for CY 2020 for the Medicare Physician Fee Schedule (released on July 29).

The ISASS letter addressed several issues of relevance to ISASS member reimbursement regulation, including the Medicare payment for 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 a proposed value of 9.03 work RVU, but that 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 discectomy 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, but ISASS stated in their comment letter that this value is vastly too low. The written comment from ISASS are consistent with met previous ISASS comments to 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 addition to the extensive comments on 27279, ISASS also commented on proposed malpractice RVUs and proposed updates to the definitions and payments for Evaluation and Management (E/M) office visit services (CPT 99201-99205, 99211-99215).

CMS will review comments and issue a final rule for the CY 2020 Medicare Physician Fee Schedule in November, to go into effect January 1, 2020.

Read ISASS 2020 Medicare Physician Fee Schedule Proposed Rule Comment Letter Final.