Medicare Priced Your Remote Monitoring Program Twice

CMS priced 99454 twice in the same rule.

Addendum B of the CY2027 physician fee schedule proposed rule gives it 1.25 practice expense RVUs. A separate file in the same downloads folder, posted eleven days later, gives it 0.29.

Both are CMS's. Both describe the same code in the same year. At the proposed nonqualifying APM conversion factor of $32.8409, the first is $41.05 and the second is $9.52.

"Which of the two numbers in this rule is the one you should be modeling?"

The File in the Downloads Folder

It is called CY 2027 PFS Proposed Rule Fully Implemented PE RVUs, and its header row says exactly what it is:

"The displayed values in this file represent the PE RVUs that would have resulted had the CY 2027 proposals, other than the 5% stabilization factor, been fully implemented without the statutory phase-in of significant RVU decreases. These PE RVUs are calculated without the 5% PE stabilization factor and with the removal of the entire impact of the IPCI."

Three brakes come off in that sentence, and they are the three things CMS proposed in the practice expense methodology this year.

The first is the indirect practice cost index. CMS is proposing to delete steps 12 through 17 of the PE methodology, the ones that run the IPCI, on the grounds that they "effectively favor the aggregate specialty-level survey data over the code level inputs and allocators." That happens over two years: in year one only half the measured IPCI variation gets applied, in year two none of it does. CY2027 is year one.

The second is proposed step 19, a new PE stabilization factor. No PE RVU may increase or decrease by more than 5 percent against the prior year. CMS is candid about why it is needed: the IPCI, "because it is rooted in static PE/HR data, effectively resulted in stabilizing year-to-year changes in PE RVUs," so pulling it out means something else has to hold the line.

The third is the statutory phase-in at section 1848(c)(7), which caps any non-new, non-revised code at a 19 percent total-RVU reduction in one year and spreads the rest into the next.

Stack all three and a code can only fall so fast. Take them off and you get the file.