The comment period for the 2015 Medicare Physician Fee Schedule proposed rule ended last week and radiology and imaging-related organizations expressed their concerns about a number of issues, such as the potential for significant reimbursement reductions in radiation oncology services.
One area of particular interest to these organizations has to do with the payment for the secondary interpretation of images.
Currently, Medicare reimburses for secondary interpretation of images only in unusual circumstances. But as CMS acknowledges image sharing, technologies are becoming increasingly commonplace, making it much easier for providers to share images with each other for purposes of getting secondary interpretations, rather than order duplicative imaging procedures.
To that end, CMS, in its proposed rule, solicited comments on whether Medicare should expand payment for secondary interpretations, particularly when that would result in savings to the Medicare program.
"We strongly support payment policies that promote the use of imaging to avoid unnecessary and invasive follow-up procedures and we agree with CMS that secondary interpretation of images can save money for the Medicare program by preventing the need for such unnecessary procedures," the Medical Imaging and Technology Alliance stated in its comment letter, a view generally backed by the other organizations such as the American College of Radiology and the Radiology Business Management Association.
More specifically, when CMS asked whether allowing more routine payment for secondary interpretations is likely to generate cost savings to Medicare by avoiding duplicate exams, the ACR responded that not only would payment for secondary interpretations reduce unnecessary repeat studies, it also would result in a reduction in patient radiation exposure.
ACR also argued that routine payment for secondary interpretations shouldn't be restricted to high-cost imaging services like MRI and CT, since all radiology studies "have the potential to be clinically relevant."
If, as advocates argue, the implementation of image technologies is actually making it easier for physicians to perform secondary interpretations and to reduce or eliminate duplicate scans, that should be music to CMS' ears.
After all, according to an article in the Wall Street Journal last year, Medicare spent about $10 billion on medical imaging in 2010, approximately 10 percent to 20 percent of which was estimated to be for duplicate exams.
CMS, the ball is in your court. - Mike (@FierceHealthIT)