The Medical Imaging and Technology Alliance (MITA), a division of the National Electrical Manufacturer's Association, has submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the agency’s recently-released "Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2008 Payment Rates; Proposed Changes to the Ambulatory Surgical Center Payment System and CY 2008 Payment Rates." The proposed rule calls for bundling radiology drugs and services into procedural codes for one fixed fee.
In a letter explaining its concerns to Acting CMS Administrator Kerry Weems, MITA vice president Andrew Whitman said, “MITA has accepted packaging of carefully selected ancillary services into those principal procedures with which they are always or nearly always performed. However, we have numerous concerns about the sheer scope and approach of the packaging policies outlined in the proposed rule.”
MITA is concerned that the CMS has not proposed regulatory standards to guide and support the packaging proposals, nor sufficient information to properly evaluate them. The Alliance is also concerned that the scope and breadth of the proposals could undermine the structural integrity of the ambulatory payment classification (APC) system, and create hospital payment anomalies and impermissible savings relative to budget neutrality requirements.
In the letter, MITA made the following recommendations:
• Delay the packaging proposals for at least one year, and in the interim, develop and communicate the principles and regulatory standards likely to govern packaging approaches.
• Treat all radiopharmaceuticals as drugs entitled to separate payment and not subject to packaging if their costs exceed the dollar packaging threshold.
• Provide pass-through payments for new technologies and refrain from premature clinical assignment or packaging of items or services that may be eligible for APC pass-through payments.
• Create a separate clinical APC that reflects all of the costs associated with PET/CT, allowing the CMS payment structure to more adequately reflect all the resources performed with PET/CT; and continue to pay separately for diagnostic radiopharmaceuticals as specified covered outpatient drugs.
• Reassign coronary CT and CTA procedures to an appropriate New Technology APC for CY 2008 and continue to pay separately for contrast agents.
“CMS must look to the future as new developments in molecular, cellular, functional and genetic imaging promise a new era of prediction and prevention of disease, not just diagnosis and treatment,” according to Whitman.