The American College of Radiology has submitted comments to the Center for Medicare & Medicaid Services on the Medicare Physician Fee Schedule (MPFS) Proposed Rule, urging CMS not to adopt payment policies that will result in significant reimbursement cuts for radiology and radiology oncology services.
The letter, written in the name of Harvey L. Neiman, M.D., addressed the following issues:
- Impact of the Hospital Outpatient Prospective Payment System Proposed Rule on the Medicare Physician Fee Schedule
- Using Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Rates in Developing Practice Expense Relative Value Units
- Ultrasound Room Equipment Recommendations (General)
- Ultrasound Equipment Input Recommendations for Particular Services
- Direct Practice Expense Inputs for Stereotactic Radiosurgery Services
- Misvalued Codes; Revising the Medicare Economic Index
- Utilization Rate; Multiple Procedure Payment Reduction; Quality Provisions
In the letter, ACR reminded CMS that data shows that Medicare spending for imaging services have been "on a steady decline," and that CMS should not use "outdated language that points to significant growth in spending when Medicare data shows the opposite trend."
Considering the impact on radiology from factors such as the Deficit Reduction Act, the statutory change in the equipment utilization rate, interest rate changes, and changes in practice expense inputs, ACR urged that CMS "consider implementing a reimbursement dampening policy."
Reimbursement rates have been on the decline since 2006-07, the letter concluded, and Neiman said ACR is "deeply concerned" that the latest proposed imaging services cuts will undermine quality care.
"It is important that CMS recognize the cumulative impact of the various legislative and regulatory policies reducing reimbursement of imaging services," Neiman said. "If the proposed policies for 2014 are implemented patient access will be adversely affected. A dampening policy would limit the total amount a specific procedural code could be reduced in a given year."
ACR also has submitted a letter to CMS regarding the Hospital Outpatient Prospective Payment System (HOPPS) Proposed Rule requested, asking that CMS not implement the data generated by the CT and MR cost centers. Instead, ACR wants CMS to continue to set hospital payment rates for CT and MR studies using the diagnostic radiology cost-to-charge ratio.
The CMS proposal to use FY2011 cost data to establish separate cost centers for CT and MR would, according to the ACR, cut hospital outpatient payments for CT and MRI studies by 18 to 38 percent.