A recent recommendation from the Medicare Payment Advisory Commission (MedPAC) to change the formula that determines physician reimbursement rates for advanced imaging procedures "is based on a deeply flawed survey that should be rejected," according to the Access to Medical Imaging Coalition (AMIC). Specifically, MedPAC has called on the Centers for Medicare and Medicaid Services (CMS) to significantly increase the formula's assumption about the amount of time that advanced imaging equipment is used by physicians by 40 percent, which will further slash reimbursement rates.

According to the coalition, the MedPAC report relied on a statistically insignificant sample size of only six urban medical imaging centers, rather than a representative national sampling.

Second, MedPAC surveyed only CT and MR, yet its recommendation covers imaging modalities not surveyed, such as PET and nuclear medicine. Third, the methodology that MedPAC used to make its utilization assumptions does not account for the health or age of the patient, the single biggest determinant affecting the length of an imaging appointment, and ultimately utilization rates. Older and less healthy patients require longer preparation and exam time, which is highly relevant when talking about the Medicare population, according to AMIC.

"MedPAC's survey doesn't hold water," said Tim Trysla, executive director of AMIC. "It's astonishing that MedPAC only surveyed two imaging modalities in six cities instead of a true national survey that includes imaging services in rural America. Even MedPAC staff has acknowledged that Congress should provide CMS with adequate resources and flexibility to improve the accuracy of what Medicare pays. AMIC agrees: before accepting flawed recommendations based on an incomplete survey that would lead to additional drastic cuts, CMS and the HHS Secretary should be equipped with resources to gather conclusive survey data on equipment use rates to make payment decisions."

Patient access threat

The impact of increasing equipment use rates would be to deny providers adequate payment for the services they provide, potentially resulting in access problems for Medicare beneficiaries, which would mostly likely hit patients in rural regions of the country first, according to AMIC. The reductions in Medicare reimbursements for imaging services would further deepen cuts that are already being implemented as a result of the Deficit Reduction Act of 2005 (DRA) and threaten to disrupt access to patient care.

According to the Government Accountability Office (GAO), the DRA resulted in $1.64 billion in Medicare cuts in 2007 alone, the first year cuts were implemented, which was three times larger than what Congress intended. The GAO also found that utilization of advanced imaging services has slowed significantly; suggesting that further cuts could endanger the availability of these services.

Accurate data need

AMIC pointed to new data collected by the largest community-based cancer care network as further proof that MedPAC made incorrect assumptions about the amount of time advanced imaging equipment is in use. Data collected by US Oncology shows that, based on annualized utilization data from the first half 2007, 94 percent of CT machines and 95 percent of PET machines operated under 75,000 minutes, which is equal to the current assumption of 50 percent utilization. US Oncology's data also shows that 56 percent of CT machines and 57 percent of PET machines operated under 37,500 minutes, or 25 percent utilization.

AMIC also called for a new public-private partnership with CMS and the Department of Health and Human Services (HHS) that would collect data from equipment scanning logs that measure the actual time an imaging machine is turned on and in use.