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The commenters stated that the methodology prescribed in the legislation would result in a payment range of approximately $500 to 700/cm 2

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Overall, to address these issues, the nominator specifically requested that CMS restore the work RVU values to those originally recommended by the RUC in 2019, stating that CMS' previous crosswalk to neonatal transfusion described by CPT code 36440 ( Push transfusion, blood, 2 years or younger ) was inappropriate given the significant differences in work intensity levels and required expertise between the procedures

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