In the July 29, Medicare Physician Fee Schedule Proposed Rule, CMS indicated a proposed value 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 of 19.88 Total RVUS which maintains the current value of 27279.

ISASS had previously asked CMS to reconsider the value of this CPT code as “misvalued,” and CMS agreed that it may be misvalued and assigned a review of the value by the AMA RUC.  ISASS, along with other medical societies—icluding NASS, AANS, and AAOS—conducted a physician survey and recommended increasing the RVUs for 27279.  The RUC, however, did not accept this recommendation and CMS cited the RUC’s recommendation in the proposed rule.

However, CMS also indicated they will consider additional written comments from stakeholders on whether CPT code 27279 should be assigned a higher work RVU to achieve payment parity with CPT code 27280, Arthrodesis, open, sacroiliac joint, including obtaining bone graft, including instrumentation, when performed.

The section of the proposed rule addressing CPT codes 27279 and 27280 is below.

“(8) Arthrodesis – Sacroliliac Joint (CPT Code 27279)
In the CY 2018 PFS final rule (82 FR 53017), 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) was nominated for review by stakeholders as a potentially misvalued service. We stated that CPT code 27279 is potentially misvalued, and that a comprehensive review of the code values was warranted. This code was subsequently reviewed by the RUC. According to the specialty societies, the previous 2014 survey of CPT code 27279, was based on flawed methodology that resulted in an underestimation of intraoperative intensity. When CPT code 27279 was surveyed in 2014, there was a low rate of response. Due to the dearth of survey data and the RUC’s agreement with the specialty society at the time that the survey respondents had somewhat overvalued the work involved in performing this service, the RUC used a crosswalk to 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) to recommend a work RVU of 9.03.The specialty societies indicated that with increased and broader utilization of this technique, the 2018 survey is a more robust assessment of physician work and intensity and provides more data with which to make a crosswalk recommendation. According to the RUC, there is no compelling evidence that the physician work, intensity or complexity has changed for this service.

“We are proposing to maintain the current work RVU of 9.03 as recommended by the RUC. A stakeholder stated that maintaining this RVU would constitute the continued undervaluation of this service, and that this would incentivize use of a more intensive and invasive procedure, CPT code 27280 (Arthrodesis, open, sacroiliac joint, including obtaining bone graft, including instrumentation, when performed), as well as incentivize this service to be inappropriately furnished on an inpatient basis. This stakeholder has requested that, in the interest of protecting patient access, we implement payment parity between the two services by proposing to crosswalk the work RVU of CPT code 27279 to that of CPT code 27280, which has a work RVU of 20.00. While we are proposing the RUC-recommended work RVU, we are soliciting public comment on whether an alternative valuation of 20.00 would be more appropriate. This alternative valuation would recognize relative parity between these two services in terms of the work inherent in furnishing them. We are proposing the RUC-recommended direct PE inputs for CPT code 27279.”

ISASS will comment on the proposal and encourage CMS to adopt a more equitable and appropriate RVU for 27279.