The PFA asked the CMS to crosswalk footwear devices listed under the A-codes to similar devices listed under L-codes. That would have given the CMS more current usual and customary pricing for those devices. However, CMS was required to go back to the first fee schedule, established in 1989, for a base fee to determine pricing for 2005. That is why 2005 fees are lower than 2004 numbers.

Randy Stevens