CMS Puts MPPR Imaging Cuts Back on the Table

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To find budget savings that would help cover a 7% increase in payments to Family Medicine physicians and other Centers for Medicare and Medicaid Services (CMS) wants, several proposed ideas for cutting reimbursement are back in play in the 2013 Medicare Fee Schedule Proposed Rule posted last Friday. This includes the unpopular multiple procedural payment reduction (MPPR) of 25% on the professional component for CT, MR and ultrasound services — a proposal more than 250 members of the House have said they are against by signing on to the Diagnostic Imaging Services Access Protection Act (H.R. 3269).

"They basically dusted off the old language and inserted it again," says Cindy Moran, assistant executive director of government relations for the ACR.

She added that she and the ACR are going to come back to CMS with the same objections the had last year. The first is that the logic behind the MPPR is flawed. It is no more efficient for two separate radiologists to interpret two separate studies for the same patient on the same day than it is for them to do it on two separate days. The second is that it would be operationally impossible for a radiology practice to determine how to properly code multiple procedures to Medicare.

In 2011, CMS backed down. It only kept the MPPR cut to the PC when a single radiologist interpreted two or more studies for a patient in the same session. However, Moran does not expect CMS to back down twice. That means that the pressure is on to get H.R. 3269 passed in the House, where Moran says it has a shot, and on to the Senate, where it may face a tougher fight.

Cindy Moran"It is really going to be our only hope," she says.

Without either CMS backing down or passage of H.R. 3269, imaging interpretations furnished by multiple physicians in the same group practice on or after January 1, 2013, will be subject to the MPPR to the professional component as well as the technical component of advanced imaging procedures.  

In addition, CMS is proposing to expand the MPPR policy to the TC by cutting cardiovascular and ophthalmology services by 25 percent.  Many of the studies affected by this rule are in the interventional radiology (75600-75893) and nuclear medicine (78445-78496) codes series of CPT, the ACR states.

The ACR is organizing meetings between members and their congressional representatives while the legislators are at home in their districts during the August Congressional recess. In addition, a "Call to Arms" for ACR members is being organized and should be announced in about two weeks, Moran says.

The ACR is also going to the court of public opinion. In a release to news media, it did not mince words, calling the proposed cuts to imaging "potentially dangerous, unfounded and unnecessary." Making its case, the ACR pointed out that the types of patients that require multiple imaging scans and interpretation by different specialists are suffering for immediately life threatening illnesses or injuries that require a team of health care providers to diagnose and treat.

"These cuts discourage doctors from working as a team and pull the rug out from under the very physicians working to save these people’s lives,” said Paul Ellenbogen, MD, FACR, chair of the American College of Radiology Board of Chancellors in the statement.

Other specialists who are now also affected by the cuts may come to the aid or radiology, Moran says. However, they will need to work together to make sure the addition of more voices does not accidentally confuse the issue.

"Other people crying foul helps, but sometimes it muddles the message," she says.

There is also a challenge posed by the nature of the cuts. CMS's focus on prevention through increased funding for primary care and new funding for care coordination following a hospital or nursing facility stay is coming at the expense of specialty care.

"It is a very concerted effort to redistribute income," Moran says. "They are taking money from specialists and giving it to primary care."

Pitting one group of physicians against another is a good way to split the opposition in politics, and Moran warns that this is indeed a political game.