In the Centers for Medicare & Medicaid Services’ (CMS’) 2015 Medicare Physician Fee Schedule (MPFS) proposed rule, 80 codes were identified as “misvalued” by CMS, of which 20 percent pertained to radiology.
Overall, however, the proposed 2015 MPFS changes would have the biggest impact on radiation oncology and radiation therapy centers, which would see the biggest drops in reimbursement.
According to an analysis of the proposed rule conducted by the American College of Radiology (ACR), the overall reimbursement impact on total allowed charges by specialty is as follows:
- Radiation Therapy Centers: -8 percent
- Radiation Oncology: -4 percent
- Radiology: -2 percent
- Interventional Radiology: -1 percent
- Nuclear Medicine: 1 percent
- Cardiology: 1 percent
- Family Practice: 2 percent
Cuts to radiography procedures are mostly responsible for the dip in radiology reimbursement, with CMS citing improved efficiencies from the transition from analog to digital in its decision to adjust practice expenses for these procedures. CMS supports using minutes on a desktop computer as a proxy for the PACS workstation as a direct expense and removing film supply and equipment items. In addition, MRI of the abdomen and CT of the thorax are some of the individual codes facing reductions.
CMS also proposed deleting mammography G-codes for CY 2015 in favor of CPT codes, though it does have concerns about the current values of those CPT codes as they have not recently been reviewed. Until these reviews can be conducted, CMS proposed valuing the CPT codes using the RVUs previously established for the G-codes, which would result in a temporary reimbursement increase, according to the ACR.
The headline for radiation oncology and radiation therapy centers is that CMS proposed treating radiation treatment vaults as an indirect practice expense rather than a direct practice expense. CMS determined that vault costs are more similar to building infrastructure costs than medical equipment costs, and the proposed rule would remove the radiation treatment vault as a direct practice expense from a total of 14 radiation treatment procedures. In a statement, the American Society for Radiation Oncology said it was “very concerned” by the proposed cuts and “their potential impact on patient access to cancer care.”
CMS indicated it will also examine payment for secondary interpretation of images, and asked for comments on circumstances in which it would be appropriate to allow more routine Medicare payment for a second professional component for radiology services. The agency is interested in determining whether such a policy would reduce the incidence of duplicate imaging.
The full proposed rule will be published in the Federal Register on July 11, with CMS accepting comment until September 2.