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The nominator further asserted that this code family is potentially misvalued because surgical practice for these procedures has evolved since 1995

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We responded to concerns raised by commenters about potential duplicative payment and potential misreporting of the code, noting that when procedures or other services are reported on the same day by the same billing practitioner as a significant, separately identifiable O/O E/M visit (the base codes that the visit complexity add-on code can be billed with), we believed that the services involve resources that are sufficiently distinct from the costs associated with furnishing stand-alone O/O E/M visits to warrant a different payment policy (88 FR 78971)

2021;22:e13091

We recognize the Recommendation Group's concerns, but emphasize the tradeoffs between accuracy and reliability, as described in the CY 2022 PFS final rule (86 FR 65453 through 65456)

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