The ACR has requested a delay from the Centers for Medicare & Medicaid (CMS) in all packaging initiatives for imaging and drugs until the impact of the final ruling on the 2008 hospital outpatient prospective payment system (OPPS) is further studied.
CMS issued the final rule on Nov. 1.
According to the ACR, the final rule will affect outpatient services furnished by general acute care hospitals, inpatient rehabilitation facilities, inpatient psychiatric facilities and long-term acute care hospitals.
CMS said it will extend the current packaging approach to include guidance services, image processing services, intra-operative services, imaging supervision and interpretation services, diagnostic radiopharmaceuticals, contrast agents and observation services.
By packaging and bundling these services into a single payment, CMS said it creates incentives for providers to furnish services in the most efficient way by enabling hospitals to manage their resources with maximum flexibility.
Hospitals will continue to bill the same way and CMS will bundle payments, said the ACR. However, the new approach will cause a 25 percent reduction in revenue for hospital departments for interventional radiology services, according to the association.
Six out of seven services of importance to ACR, and the reasons for the delay request:
- Guidance services: Package payment has changed for 31 healthcare common procedure coding system (HCPCS) guidance codes, including 26 radiology codes. The ACR is opposed to the imaging guidance services being bundled because none of the guidance codes are commonly done with one or only a few surgical or procedural codes, which raises the risk that these services will be underpaid.
- Imaging processing services: A package payment for image processing HCPCS codes that are reported as supportive dependent services to process and integrate diagnostic test data in the development of images, performed concurrently or after the independent service is complete. The ACR is concerned that hospitals will not place importance on the services and continue to support their availability to other specialties in the hospital if they are being inadequately reimbursed by CMS.
- Intraoperative services: A package payment has changed for intraoperative HCPCS codes for dependent diagnostic testing or other minor procedures performed during independent procedures.
- Imaging supervision and interpretation service: CMS has changed the packaging status of many imaging supervision and interpretation codes for OPPS. The ACR feels that the changes are too far reaching to be accomplished in a single cycle.
- Diagnostic radiopharmaceuticals: The packaging status will change for 47 diagnostic radiopharmaceuticals. CMS will pay separately for therapeutic radiopharmaceuticals at an average per day cost of more than $60. The ACR is concerned that the reimbursement methods for diagnostic radiopharmaceuticals will create an incentive for hospitals to shift away from advanced technologies.
- Contrast agents: All contrast media will be packaged into independent diagnostic and therapeutic procedures. The ACR believes there is insufficient justification for treating contrast agents differently from other injectable drugs administered in the hospital outpatient setting.