 
February 10, 2020 
 
The Honorable Seema Verma, Administrator 
Centers for Medicare & Medicaid Services 
Department of Health & Human Services 
Mail Stop C4-26-05 
7500 Security Boulevard 
Baltimore, MD 21244-1850 
medicarephysicianfeeschedule@cms.hhs.gov 
 
RE: Information for Future Medicare Physician Fee Schedule (MPFS) Rulemaking, Updated Spirometry Equipment 
 
Dear Administrator Verma: 
 
This letter is jointly submitted on behalf of the American Thoracic Society (ATS) and the American College of Chest Physicians (CHEST) Clinical Practice Committee. ATS/CHEST appreciate the opportunity to supply the Centers for Medicare & Medicaid Services (CMS) with invoices for spirometry services and our committee expert opinion.  
 
As part of our work with the AMA RUC, we supplied updated information that EQ040 and EQ043 are now obsolete equipment and those CMS inputs should be deleted.  At that time, we suppled one invoice for the purchase of (3) units of the current spiromety equipment.  We also noted that the invoice provided was from a large multi system hospital and was deeply discounted for equipment and not represenative for the typical physicain office purchase for new equipment, now CMS EQ041.  
 


CMS Code 
 
Category 
 
Description 
 
Useful Life 
 
Price 
 

EQ040 
 OTHER EQUIPMENT 
 Vmax 229 (spirometry testing equip, computer system) 
 8 
 50,352.98 
 

EQ041 
 OTHER EQUIPMENT 
 Vmax 22d and 62j (PFT equip, autobox, computer system) 
 8 
 47,930.00 
 

EQ043 
 OTHER EQUIPMENT 
 Vmax 29s (spirometry testing equip, computer system) 
 8 
 26,875.00 
 

 
The ATS/CHEST committee appreciates CMS in establishing EQ041 and as we noted, we recommend that CMS crosswalk all the exsiting times for the varying codes with equipment EQ040 and EQ043 to the new current EQ041 equipment. Additionaly we are attaching one more invoice that we were able to obtain from our membership and this invoice supports the $47,930 CMS price.  
 
Thank you for consideration of this additional information as you begin preparation for future rulemaking.  
 
Sincerely, 

 
  
 

Kevin Kovitz, MD 
 Omar Hussain, DO 
 

American College of Chest Physicians 
 American Thoracic Society 
 



 
 
 
 

