The indirection for variability of costs basically places a accounting hole that the motivation for "fixed" estimates was attempting to plug. Then it basically

The indirection for variability of costs basically places a accounting hole that the motivation for "fixed" estimates was attempting to plug. Then it basically becomes a regulatory accounting chasing game that costs even more to administer. Instead of verify, time and materials expended are whats billed, now to verify fair prices, you need a sample size of all the outcomes of all the procedures that started with this code and their relative weighting of occurrence, and verify all the time and materials expended for each. It all costs more for dubious benefit of a privatized multi payer model