The ACR’s updates are always some of the most well-attended events at RBMA’s educational conferences, and this afternoon’s presentation on payment policy and legislative issues looks to be no exception: Maurine Dennis and Judy Burleson of the ACR are playing to a packed house. “I’m here to talk about the good news,” Dennis began. “I promise.”
Dennis launched her portion of the talk with a list of the people who are targeting imaging. Needless to say, it goes on and on, but CMS and Congress are probably the primary snipers taking pot-shots at radiology’s reimbursement. The 2011 proposed MPFS reduces the conversion factor by 6.1% in 2011, adding to the 21.2% reduction recently delayed by Congress. “As recently as this morning, we got some information from AMA on how to calculate your payments in the interim and will get that information up on our website as soon as we can, but it’s difficult to know whether action will be taken November 30th,” Dennis said. Additionally, PPACA mandates creating a new disclosure requirement for the in-office ancillary services exception. “No one seems to be able to close that loophole,” Dennis noted, “so starting January 1, the referring physician has to give the patient options in writing.”
Misvalued codes under the MPFS are another big issue. “One of the big misperceptions out there is that imaging services are overpriced,” Dennis said. “That puts codes under the microscope. We have to justify maintaining their current value.” The Secretary of HHS will be focusing in codes with the fastest growth, new technologies or services, low RVUs, codes not reviewed since the early 90s and “other codes determined appropriate by the Secretary.” “So basically, this is the whole fee schedule,” Dennis said. “The days of review every five years are done.”
Dennis says the most egregious hit, however, is the proposed expansion of the multiple procedure reduction. Congress already expanded this from 25% to 50% for eleven code families, and is now proposing a reduction across all three modalities, even if they’re non-contiguous. “The watchword there is that they think there are economies of scale to be gained,” she noted. The biggest rationale for the move is a July 2009 GAO report about Medicare physician payments from which CMS cribbed most of the language it’s now using in its proposal.
The ACR met with CMS specifically to discuss the multiple procedure reduction. “The feedback we got was, ‘Well, you’re probably right, but here’s the thing: Congress might just come back and do this later,’” Dennis said. “We talked to them about how we’re in the process of bundling ourselves. The back-and-forth was cordial, and they seemed to get it, but who knows.” In an analysis of the impact of the proposed cuts, neuroradiologists and portable x-ray suppliers stand to benefit, while general radiology gets hit with a 12% payment reduction and IDTFs get hit with a 20% reduction.
Dennis went on to discuss the Physician Practice Information Survey, which updates the AMA’s Socioeconomic Monitoring Survey and is used to calculate practice expense. “We paid about $75,000 to participate this year, and we got hosed,” Dennis said. “Our practice expense is down 33% next year. It was good while it lasted, but the curve has definitely gone back down.” The ACR claimed the survey was not representative of radiology because it only garnered 56 usable surveys, most from hospital-based radiologists (who have no practice expenses). “We complained about the transparency and lack of access to data, we asked them to delay implementation, we asked for a transition, and CMS did agree to transition us over four years,” she said. “Still, it’s a hit.”
As for health care reform? “We were the only physician specialty targeted for reductions in the health care legislation,” Dennis said. “There were proposals that would’ve had even worse impact, but since 2008 Congressional staff have been asking for $3 billion from imaging to support other initiatives.” Dennis described the legislation’s “missing provisions”: no fix for the SGR and no tort reform. “The latest on the SGR is that Congress might not even extend it until the first of the year,” Dennis said. “They might just let it go down, and that’s what AMA is preparing for.”
Here’s a trivia question: what do the folks at the ACR call “MedPAC on steroids”? If you guessed “the Independent Payment Advisory Board,” you got it: there is no Congressional oversight built into IPAB, an intentional