ASNR Comments on Proposed CMS Rule Applying MPPR to Group Practices

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The Center for Medicare & Medicaid Services (CMS) has several health policy proposals in the Medicare Physician Fee Schedule Proposed Rule for CY2013 that have important implications for neuroradiology. ASNR submitted a letter to CMS, commenting on several of the proposals that are of interest to neuroradiology. We present a summary below, and you can read the full letter here.
The letter was a collaborative effort of ASNR Clinical Practice Committee (CPC) Leaders: Dr. Robert Barr, Dr. William Donovan, Dr. Jacqueline Bello, Dr. David Seidenwurm, Dr. Joshua Hirsch, Dr. Gregory Nicola, Dr. Raymond Tu and ASNR staff.
The work of these members on this and other Health Policy issues (including coding/reimbursement, practice guidelines and quality) is crucial to appropriate use of neuroradiology for our patients. On behalf of the Society, I thank these members for their work on these important and ongoing issues. I also encourage other Senior Members to volunteer to help on the ASNR CPC.
Here are some of the CMS proposals that the ASNR comment letter addresses and the positions that the ASNR is taking:

  • For services furnished on or after January 1, 2013, CMS will expand the Multiple Procedure Payment Reduction (MPPR) for the Professional Component and the Technical Component of advanced imaging procedures to multiple physicians in the same group practice (same group NPI).
    • ASNR opposes the MPPR application to group practices; and also the application of an MPPR in general
    • The letter made the following clarification: Each individual radiologist must approach reading an exam independently, searching for clues to a patient’s clinical condition. This independent search is akin to a direct physical exam, in which little duplication of work would be seen with a second physician examining a patient.”
  • ASNR opposes the elimination of Stroke/Stroke Rehabilitation Physician Quality Reporting System (PQRS) measures
  • ASNR supports the implementation of Radiation Dose Optimization PQRS measures

Sincerely,
Pamela W. Schaefer, MD
ASNR President

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