Federal Register, Volume 75, Number 226, November 24, 2010, Pages 71519-72652 Page: 71,913
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Federal Register/Vol. 75, No. 226/Wednesday, November 24, 2010/Rules and Regulations 71913
b. Revision/Removal of Neurostimulator
Electrodes (APC 0687)
For CY 2011, we proposed to continue
to assign CPT codes 63661 (Removal of
spinal neurostimulator electrode
percutaneous array(s), including
fluoroscopy, when performed), 63662
(Removal of spinal neurostimulator
electrode plate/paddle(s) placed via
laminotomy or laminectomy, including
fluoroscopy, when performed), 63663
(Revision, including replacement, when
performed, of spinal neurostimulator
electrode percutaneous array(s),
including fluoroscopy, when
performed), and 63664 (Revision,
including replacement, when
performed, of spinal neurostimulator
electrode plate/paddle(s) placed via
laminotomy or laminectomy, including
fluoroscopy, when performed) to APC
0687 (Revision/Removal of
Neurostimulator Electrodes), for which
we proposed a CY 2011 median cost of
approximately $1,527. For CY 2010,
these CPT codes were assigned to APC
0687, which has a CY 2010 national
unadjusted payment rate of
approximately $1,324. These new codes
were created effective for services
performed on or after January 1, 2010,
when the AMA CPT Editorial Board
deleted CPT code 63660 (Revision or
removal of spinal neurostimulator
electrode percutaneous array(s) or plate/
paddle(s)) and created new CPT codes
63661, 63662, 63663, and 63664 to
differentiate between revision and
removal procedures, and to also
differentiate between percutaneous
leads (arrays) and surgical leads (plates/
paddles). In accordance with our
standard policy, we indicated in
Addendum B of the CY 2010 final rule
that the APC assignments for these new
CPT codes for CY 2010 were new
interim APC assignments by showing
comment indicator "NI" for each new
code, and we accepted public comment
on them. We received public comments
both in response to the CY 2010 final
rule interim APC assignment and in
response to our CY 2011 proposal to
continue to assign the new codes to APC
0687. We have incorporated the CY
2010 final rule comments and responses
into the summary of the comments and
responses on our proposal to continue
to assign the new codes to APC 0687 for
CY 2011.
Comment: Commenters supported the
placement of CPT codes 63661 and
63662 in APC 0687. However, they
objected to the placement of CPT codes
63664 and 63665 in APC 0687 because,
they stated, these codes are used to
report both revision and replacement ofcommenters believed that hospital
resources are substantially greater when
neurostimulator electrodes are being
replaced rather than revised. They asked
that CMS create and require hospitals to
use four new Level II alpha numeric
codes to report these services in place
of the CPT codes. Specifically, they
asked that CMS create Level II alpha
numeric HCPCS codes for (1) Revision
of spinal neurostimulator electrode
percutaneous arrays; (2) Revision of
spinal neurostimualtor electrode plate/
paddle arrays; (3) Replacement of spinal
neurostimulator electrode percutaneous
arrays; and (4) Replacement of spinal
neurostimulator electrode plate/paddle
arrays. They stated that CMS could
continue to assign the two new HCPCS
codes for revision of electrodes to APC
0687, which has a CY 2010 national
unadjusted payment rate of
approximately $1,324. However, the
commenters suggested stated that CMS
assign the new HCPCS codes for
replacement of percutaneous electrodes
to device-dependent APC 0040
(Percutaneous Implantation of
Neurostimulator Electrodes), which has
a CY 2010 national unadjusted payment
rate of approximately $4,429. They also
suggested that CMS assign the new
HCPCS codes for replacement of plate/
paddle electrodes to device dependent
APC 0061 (Laminectomy, Laproscopy,
or Incision for Implantation of
Neurostimulator Electrodes), which has
a CY 2010 national unadjusted payment
rate of approximately $5,832. The
commenters believed that the creation
of the two Level II alpha numeric
HCPCS codes for replacement of the
neurostimulator electrode devices and
their assignment to device-dependent
APCs 0040 and 0061 are necessary to
ensure that hospitals are paid
appropriately for the cost of the
electrodes that are inserted during a
replacement procedure. One commenter
stated that an analysis of the registration
information it maintains on individual
patients, products, and associated
procedures from June 2004 to April
2010 shows that 343 lead revisions
would currently fall into CPT code
63663 or 63664. The commenter further
stated that, of these 343 cases, 22
percent were revised without a device
while 78 percent were revised with
replacement of a device (the commenter
provided aggregate information across
both CPT codes). The commenter
indicated that its data support the need
to create the new Level II alpha numeric
HCPCS codes and to assign the codes for
neurostimulator electrode replacement
to APCs 0040 and 0061. The commenterneurostimulator electrodes. The
alpha numeric HCPCS codes for the
same reason in the past and, therefore,
has a precedent for creating the Level II
alpha numeric HCPCS codes as the
commenter requested.
Response: For CY 2011, we are
assigning CPT codes 63661, 63662,
63663, and 63664 to APC 0687 as we
proposed, with a CY 2011 final rule
median cost of approximately $1,480.
We do not have CY 2009 claims data on
the cost of these codes upon which to
make an assessment of whether there is
a meaningful difference between the
cost of revising the electrodes or
replacing them. Therefore, we are not
convinced by the commenters that the
use of the CPT codes for these services
and the assignment of the codes for
revision/replacement of neurostimulator
electrodes to APC 0687 are
inappropriate. Further, the OPPS is a
payment system of averages in which
the payment for a service is based on the
estimated relative cost of the service,
including a range of supply and other
input costs, as well as other services in
the same APC that are comparable in
resource cost and clinical homogeneity.
We expect that hospital charges for a
service, which are derived from the cost
of a service, can vary across individual
patients. Therefore, we expect
variability in the estimated cost of a
service, across cases in a hospital and
among hospitals, to be reflected at some
level in the final APC relative payment
weight. Further, hospitals frequently
advise us that when we create and
require that they report Level II alpha
numeric HCPCS codes to report services
for which CPT codes exist, it imposes a
significant and costly administrative
burden on them. Hence, we prefer not
to create Level II alpha numeric codes
unless there is a strong need to do so to
administer the Medicare program,
particularly when there are CPT codes
that can be used to accurately report the
service. However, we will examine
estimated costs for these four new CPT
codes in the CY 2010 claims data we
will use to model the CY 2012 proposed
rule when that data are available.
After carefully considering the public
comments we received in response to
the CY 2010 final rule with comment
period and the CY 2011 proposed rule,
we are continuing to assign CPT codes
63661, 63662, 63663, and 63664 to APC
0687, with a CY 2011 final rule median
cost of approximately $1,480.stated that CMS has created Level II
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United States. Office of the Federal Register. Federal Register, Volume 75, Number 226, November 24, 2010, Pages 71519-72652, periodical, November 24, 2010; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc52807/m1/402/: accessed April 25, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.