AARC Comments on "G" Codes

December 20, 2001

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1169-FC
P.O. Box 8013
Baltimore, MD 21244-8013

RE: Medicare Physician Fee Schedule, Calendar Year 2002 Final Rule

To Whom It May Concern:
I am writing on behalf of the American Association for Respiratory Care (AARC) regarding the Medicare Physician Fee Schedule, Calendar Year 2002 Final Rule that appeared in the November 1, 2001, Federal Register. The AARC is a national professional association representing approximately 31,000 respiratory therapists who practice in all health care settings across the country.

The AARC wishes to comment on the section of the Final Rule regarding Respiratory Therapy Codes that appears on page 55311 of the Federal Register notice. The AARC is pleased that this section acknowledges that "in the past, services delivered by respiratory therapists or other health professionals often have not been clearly described by the existing CPT codes." In fact, the AARC believes that the health care system lacks a comprehensive list of codes that appropriately describe respiratory therapy services. Without appropriate codes, it becomes difficult, if not impossible, to properly account for the services provided by respiratory therapists to Medicare beneficiaries.

The development of these three new G codes (G0237, G0238, and G0239) to describe services to improve respiratory function appears to be a positive step toward recognizing respiratory therapy services. We do, however, have several questions regarding the implementation of these codes that we wish to address through this comment process.

1. Which health care settings are these codes applicable?
Addendum B, page 53484 of the Federal Register notice lists the relative value units (RVUs) for these three G codes, and others. Under the column for fully implemented non-facility total, the RVU for G0237 is 0.47. However, under the column for fully implemented facility total, there is a NA (non-applicable) listing. Does the NA listing indicate that these codes are not for use in the hospital outpatient setting?

2. What services are covered by these codes?
The general description for G0237 is "therapeutic procedures to increase strength or endurance of respiratory muscles, face-to-face, one-on-one, each 15 minutes (includes monitoring)." Although a general description may be appropriate for these codes, many respiratory therapists have questioned the extent to which these codes may be used to bill for their services.

3. Are these codes applicable for billing services that make up an outpatient pulmonary rehabilitation program? If so, how will these G codes affect the use of other codes outlined in individual local medical review policies for outpatient pulmonary rehabilitation?

4. If these codes are applicable for billing services that make up an outpatient pulmonary rehabilitation program, will they preclude respiratory therapists from using additional CPT codes to bill for their pulmonary rehabilitation related services?
Services such as lower extremity exercises (e.g., treadmill, bicycle, track), patient assessment, breathing treatments with medications (e.g., aerosol therapy, and MDI therapy), pre- and post program diagnostic testing (e.g., pulmonary function testing, and stress testing), and others do not seem to fit under the general description of these G codes. Will respiratory therapists be able to use these G codes in conjunction with CPT codes to describe the full range of their services?

5. Since the effective date of this Final Rule is January 1, 2002, will these G codes become operable on that date?

The AARC appreciates the opportunity to comment on this Final Rule. If you have any questions, please contact Jill Eicher, AARC Director of Government Affairs at 703/548-8538 or at eicher@aarc.org.

Sincerely,
Margaret F. Traband, MEd, RRT
President