Here we go again! Just when the DRA impact is beginning to be felt as the A/R collections period from Q4 06 morphs into the reality of weaker cash receipts in Q2 07, the American College of Radiology (ACR) Regulatory Update that I attended at the recent Radiology Business Management Association (RBMA) meeting in St Louis revealed the insipient danger that lies ahead in the shape of further cuts in reimbursement, and not only the technical component.
I continue to be extremely concerned about imaging’s vulnerability on two levels. My first concern is the unrelenting assault on diagnostic imaging in certain legislative and regulatory quarters. And, second is the continuing apathy (deer in the headlights) and lack of alignment and cohesion around the country to fight back. It seems that as with the DRA battle, the heavy lifting for the upcoming fight will be left to the Washington insiders and our representative lobbyists such as Access to Medical Imaging Coalition (AMIC), ACR, and the National Coalition for Quality Diagnostic Imaging Services (NCQDIS).
While these entities all are doing an admirable job of keeping organized imaging’s story in front of the powerful and influential, the regulators will easily circumvent radiology’s Maginot Line since there is really no credible and sustained grassroots effort to demonstrate the true impact of further cuts on patients and all stakeholders in health care. They do not sense any hue and cry from the trenches and to them this means just one thing—complacency.
Even if one accepts the premise, again articulated rather persuasively by some of the presenters at RBMA, that the DRA impact will actually have a 'cleansing' effect on the marketplace (raising the barrier to entry) as weaker providers who have underinvested in their businesses (bottom feeders) are naturally selected out in an overdue capacity shakeout, one cannot ignore that the regulatory sharks smell blood in the water. The DRA was just the first in a series, and if the lobbyists that represent us are right, the worst may be yet to come.
The supply/demand balance should be engineered in the marketplace, not in DC. To do otherwise is rationing, plain and simple.
A case in point: According to Maureen Spillman Dennis, the ACR’s senior director for economics and health policy, in her address to the RBMA attendees, MedPAC and CMS will propose this year that the imaging equipment utilization policy be changed from the current 50% to at least 70%. In their 2006 utilization survey, MedPAC concluded that the calculation should really be 100% in physician offices and IDTFs. Will we be comfortable with 'settling' for splitting the difference and compromising in the middle?
To put this in perspective for those who do not typically follow the arcane world of reimbursement, by the ACR’s calculation a 25% increase (from 50% to 75%) will result in a whopping 33% cut in reimbursement in the TC imaging codes. This will have a devastating impact on even the most successful radiology practices, since many managed care payers are already salivating about the possibility of piggybacking their rates on the new Medicare payment schedule.
Add to this an anticipated adjustment in the SGR calculation in the Medicare Physician Fee Schedule where it appears that a replacement for the conversion factor could focus attention yet again on an opportunity to 'adjust' reimbursement to radiology, affecting not just the TC but the professional component as well.
Unlike what happened with the DRA whose run-up was largely missed by everyone, we cannot let these new attempts to ration radiology services to go unanswered by those who will be affected by the impact. We need to heed the example of Florida-based Manatee Diagnostic Center’s Davis Graham, who I have now seen in action at a few national conferences. He is always there. He is always vocal in defense of imaging. He is always looking for advice and guidance from those in positions of influence. He always asks what else can be done. And he always fights for his profession, and asks others to join in the battle and do what they can: payors, providers and vendors alike.
We should all be inspired by Mr. Graham and follow his example by devoting resources at the local level to stay actively engaged in the process of fighting for our businesses, our profession, and our livelihood. I will continue to commit the resources of this institute and this newsletter, which now reaches nearly 20,000 imaging