The Centers for Medicare and Medicaid Services (CMS) has released the 2015 Medicare Physician Fee Schedule proposed rule and like the healthcare community as a whole, as reported by FierceHealthcare, it provides somewhat of a mixed bag for radiology.
The proposal calls for reimbursement cuts of 2 percent for radiology, 4 percent for radiation oncology, 8 percent for radiation therapy centers and 1 percent for interventional radiology. The proposal also would result in a 1 percent increase for nuclear medicine.
Under the Affordable Care Act, CMS is mandated to identify and review what it considers to be potentially misvalued codes and to make adjustments when appropriate. According to the American Society for Therapeutic Radiology and Oncology (ASTRO), the proposal that is mostly responsible for the significant cuts for radiation oncology and radiation therapy centers would remove the radiation treatment vault as a direct practice expense input from radiation treatment procedure codes.
ASTRO, commenting on the proposed rule, said the policy change would impact a number of oncology treatment codes and affect radiation oncology practices differently based on their service mix. "ASTRO is very concerned by these proposed cuts and their potential impact on patient access to cancer care," it said.
CMS didn't include any new proposals for the Multiple Procedure Payment Reduction relating to medical imaging, but did propose a change to mammography codes, suggesting that G codes for mammography be discontinued beginning in 2015 and that mammography be paid for using existing CPT codes. CMS does "not believe there is a reason to continue the separate use of the CPT codes and the G-codes for mammography services since both sets of codes would have the same values when priced based upon the typical digital technology."
CMS also is examining the issue of whether and under what circumstances it's appropriate for Medicare to provide coverage when physicians provide interpretations of existing images, and whether the uncertainty about the question is deterring physicians from utilizing existing images and avoiding the costs associated with new imaging studies.
Consequently, CMS is looking seeking comment on these questions:
- Which radiology services are physicians currently conducting secondary interpretations, and what, if any, institutional policies are in place to determine when existing images are utilized? To what extent are physicians seeking payment for these secondary interpretations from Medicare or other payers?
- Should routine payment for secondary interpretations be restricted to certain high-cost advanced diagnostic imaging services, such diagnostic magnetic resonance imaging, computed tomography, and nuclear medicine (including positron emission tomography)?
- How should the value of routine secondary interpretations be determined? Is it appropriate to apply a modifier to current codes or are new HCPCS codes for secondary interpretations necessary?
- Other than hospital settings, are there other settings in which claims for secondary interpretations would be likely to reduce duplicative imaging services?
- Is there a limited time period within which an existing image should be considered adequate to support a secondary interpretation?
- Would allowing for more routine payment for secondary interpretations be likely to generate cost savings to Medicare by avoiding potentially duplicative imaging studies?
- What operational steps could Medicare take to ensure that any routine payment for secondary interpretations is limited to cases where a new imaging study has been averted while minimizing undue burden on providers or Part B contractors.