Proposed Rule
https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-15948.pdf
Start on page 128 of the proposed rule.
(a) Invasive Cardiology: Consistent with the previous MP RVU update, we continued
to classify invasive cardiology services (cardiac catheterizations and angioplasties) that are
outside of the surgical HCPCS code range as surgery for purposes of assigning specialtyspecific
risk factors. We note that since the previous MP RVU update some invasive
cardiology service HCPCS codes have been revised. Therefore, we modified the list of
invasive cardiology services outside the surgical HCPCS code range that are to be considered
surgery in order to correspond conceptually to the list of service codes used for the CY 2010
MP RVU update. We continue to believe that the malpractice risk for cardiac catheterization
and angioplasty services are more similar to the risk of surgical procedures than most
nonsurgical service codes. As such, we applied the higher cardiology surgical risk factor to
cardiology catheterization and angioplasty services.
For the CY 2015 MP RVU update, we examined the possibility of classifying injection
procedures used in conjunction with cardiac catheterization as surgery (for purposes of
assigning service specific risk factors). After careful consideration, we believe that injection
procedures, when furnished in conjunction with cardiac catheterization, are more akin to the
malpractice risk of surgical procedures than most non-surgical services. Therefore we applied
the surgical risk factor to injection procedures used in conjunction with cardiac catheterization.
Table 15 shows the invasive cardiology services and injection services furnished in conjunction
with cardiac catheterization to be considered as surgery for purposes of assigning specialtyspecific
risk factors.
Table 15: Services Outside of Surgical HCPCS Code Range Considered Surgery
HCPCS Code Short Descriptor
92920 Prq