ACR challenges CMS on proposed rule changes

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The American College of Radiology (ACR) strongly criticized proposed rule changes to the 2012 Medicare Physician Fee Schedule in a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Donald Berwick, MD, and specifically challenged the rationale for further extending multiple procedure payment reductions (MPPR).

Under the proposed rule change, a MPPR of 50 percent would be implemented to the professional component of MRI, CT and ultrasound services provided to the same patient during the same session. The reduction in payment would ostensibly be justified by efficiencies present when a physician provides multiple services at the same time.

But the ACR said there are no more than 5 percent efficiencies in the professional component (PC) when multiple imaging services are provided together, a far cry from the proposed 50 percent MPPR.

“It appears that CMS’ decision to apply an MPPR to the PC of diagnostic imaging services is rooted in the incorrect assumption that there are considerable efficiencies when radiologists interpret successive imaging studies during a single patient visit,” wrote Harvey Neiman, MD, CEO of the ACR. “However, radiologists are morally and professionally obligated to expend an equal amount of time, effort and skill on interpreting images, regardless of whether or not a previous examination has been performed on the same day.”

The letter also called into question CMS’s interpretation of a 2009 Government Accounting Office (GAO) report which used a CT of both the abdomen and pelvis as an example of the type of services which could yield efficiencies when provided together. ACR said this represented a best-case scenario, and many other combinations of services may not provide the same level of overlap.

In order to find additional efficiencies, the GAO recommended a systematic review of services commonly furnished together, but cautioned against generalizing the existence of efficiencies across all services. The proposed rule change does just that, however, by mandating a blanket 50 percent MPPR, according to the ACR.

The ACR also said the actual level of savings may not reflect CMS’ projections. According to CMS estimates, the result of the new rules will be a reduction in imaging payments of $100 million, with an impact of only 1 percent to radiologists’ relative value units. An analysis conducted by the Radiology Business Management Association cited in ACR’s letter shows the actual reduction to be an average of 5 percent, with trauma and cancer centers facing a payment reduction of up to 8 percent.

The ACR also cited a study published in the September issue of Journal of the American College of Radiology that showed that efficiencies are highly variable and are, at most, only one-tenth of what policymakers contend.

“This supports our reasoning that the more complex patients are more likely to require multiple examinations, and that the proposed MPPR policy inappropriately targets providers caring for these complex patients,” wrote Neiman.

Potential savings would also be undermined by the high likelihood that payments to physician offices would decrease and shift toward hospital outpatient facilities where the costs to Medicare are higher, according to the letter.

The ACR also urged CMS to reconsider additional bundling of payments for many imaging procedures commonly performed in parallel.

To read the letter, click here.