CMS Proposes More Pain for Imaging in 2011

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CMS is proposing a new round of cuts to the imaging technical component by extending the multi-procedural payment reduction (MPPR) across all CT, MRI, and ultrasound studies performed on the same patient in the same day in its proposed rule for the 2011 Medicare Physician Fee Schedule. As mandated by Congress, the discount increased from 25% to 50% on July 1.

In addition to being expanded to impact all CT, MRI, and US studies, the discount as proposed would apply even if a subsequent study were performed on a noncontiguous body part and using a different one of the three modalities.

According to Pam Kassing, MPA, RCC, senior economic advisor, the American College of Radiology (ACR), the ACR particularly is concerned about applying the MPPR across modalities.

“We demonstrated to CMS that the efficiencies for contiguous body areas within the same modality in the same session realized some economies,” Kassing notes in an email. “The level of saving varied but none of the CT, MR or US scenarios produced savings up to 50%.

“Expanding this policy to noncontiguous studies and across modalities on the same patient, same physician, same day cannot be based on any efficiencies in resources. Each of these studies requires a separate set-up and separate resources to accomplish the task.”

Noting that the Patient Protection and Affordable Care Act (ACA) requires CMS to identify misvalued services in the MPFS, the agency writes in the proposed rule: “There is inherent duplication in the PE [practice expense] associated with those services which are frequently furnished together, so reducing PFS payment for the second and subsequent services to account for the efficiencies in multiple service sessions may be appropriate.

“Consistent with this provision of the ACA, we are proposing a limited expansion of the current MPPR policy for imaging services for CY 2011… ”

A summary posted on the American College of Radiology (ACR) web site estimates the impact of the changes to the multiple procedure rules and the practice expense relative values to be 20% for IDTFs when fully implemented. Interventional radiologists would take a 9% hit; nuclear medicine a 6% hit; and cardiology a 5% hit.

To carry out the Congressional mandate to identify misvalued services, CMS plans to look at seven categories of codes. Because a significant number of radiology codes fall into these categories, the ACR states in its summary that close attention will be paid.

Those seven areas are: codes and families of codes for which there has been the fastest growth; codes or families of codes that have experienced substantial changes in practice expenses; codes that were recently established for new technologies or services; multiple codes that are frequently billed in conjunction with furnishing a single service; codes with low relative values, particularly those often billed multiple times for a single treatment; codes that have not been subject to review since the implementation the implementation of the resource-based relative value scale; and other codes deemed appropriate by the Secretary.

Other changes proposed for 2011:
• CMS will implement the ACA mandated equipment utilization rate of 75%, putting an end to the phasing in of the 90% rate previously set by CMS;
• CMS has proposed including other imaging modalities in the mandate that physicians providing CT, MRI, and PET under the in-office ancillary services exception provide a list of 10 other providers within a 25-mile radius; and
• CMS proposes a –6.2% update to the professional component as per the SGR formula. This is on top of the 21.2% cut delayed by Congress through November.