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Peds Win Per Component Vaccine Admin Codes, Lose Requested PE RVUs

Pediatricians who were thrilled with CPT 2011’s move to paying vaccines per component got a setback from Medicare’s rejection of the recommended RVUs for new vaccine administration codes 90460 and 90461.

The Relative Update Committe recommended that the 2011 Medicare Physician Fee Schedule and Resource Based Relative Value Scale assign 0.20 practice expense (PE) RVUs to 90460 and 0.16 PE RVUs to 90461. But CMS disagreed with the proposal. “We disagree with the recommendations and will maintain 0.17 RVUs for code 90460 and 0.15 RVUs for code 90461 since these codes would be billed on a per toxoid basis,” said Kenneth Simon, MD, MBA, Senior Medical Officer, Center for Medicare and AMA CPT Editorial Panel Member, in “Medicare Physician Payment Schedule 2011 Changes and Beyond” at the CPT® and RBRVS 2011 Annual Symposium on Nov. 10, 2010.

The increased PEs represent an increase in RVUs from the 2010 values for comparable codes 90465/90467 and 90466/90468. The RUC requested the increase in value due to increased time for patient education. Since the new codes are valued per component, CMS felt no increase was warranted.

CMS assigned RVUs to 90460 and 90461 by crosswalking them with the values of the noncounseling vaccine administration codes 90471 and 90472. This means that new code 90460 has the same RVUs as 90471, and each unit of 90461 has the same RVUs as 90472.

The work and total RVUs for the codes include:

<td width="203"

Code PE  RVU  RUC Proposed PE  RVU MPFS Accepted Total RVUs
90460 0.20 0.17 0.59
90461 0.16 0.15 0.3

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CPT 2011 Begs CMS Reexamination of Time as Averages or Thresholds

All that fine green print on time in your E/M CPT 2011 manual boils down to one thing: you can round to the closest time code.
But that advice from CPT contradicts Medicare’s threshold time guideline.
CPT Treats Times as Averages
 CPT 2011 indicates…

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