The Center for Medicare & Medicaid Services (CMS) has several proposals pending 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. Two of these, while important, are technical issues. The third, a proposed major reduction in professional payment reduction for second and subsequent services performed during the same session, could have serious consequences for the availability of imaging services for these patients.
In order to achieve informed rule making, CMS needs the input of knowledgeable people who can provide expert input. The letter was a collaborative effort of ASNR Clinical Practice Committee Leaders: Dr. Robert Barr, Dr. William Donovan, Dr. Joshua Hirsch, Dr. David Seidenwurm, Dr. Gregory Nicola, and ASNR staff, and signed on behalf of the ASNR by Dr. David Hackney, in his capacity as President.
The work of these members on this, and with the American Medical Association, the CPT editorial panel, and the RUC are 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, and to join, or maintain membership in, the AMA.
Here is a short summary of the CMS proposals that the ASNR comment letter addresses and the positions that the ASNR is taking:
Proposed Expansion of Multiple Procedure Payment Reduction (MPPR) Rule: CMS is proposing a 50% payment reduction for the professional component of advanced imaging services for the second and subsequent service administered to the same patient, during the same session.
ASNR is opposing the MPPR expansion for the following reasons:
Each Image Requires Individual Interpretation
Actual Efficiency Gains are Much Lower than 50 Percent
GAO and MedPAC Recommendations Based on Flawed Assumptions
MedPAC Recommended that CMS should Analyze Efficiencies and Suggested that Efficiencies May Vary by Image Type
Concerns that Proposal is Influenced by Confirmation Bias
Proposal of 50 Percent Arbitrary
No Data Suggesting that there are Any Efficiency Gains in Physician Liability Exposure
Duplicative Payment Reduction
Five-Year Review Proposal: CMS currently has a formal five-year review. The Relative Value Scale Update Committee (RUC) also has an annual review for CPT codes. This annual review covers 5-year review issues, including misvalued codes. CMS has proposed to eliminate the formal five-year review, as it believes this to be duplicative of the annual review. ASNR agrees with this proposal.
Radiology Physician Quality Research System (PQRS) Proposed Measures Group: ASNR welcomes the proposed PQRS measures group, and makes following suggestions:
More specific name for measures group
Reportable by both the claims-based and registry-based methods (instead of only registry)
Consider dividing into two smaller measures groups (as the proposal has 10 individual measures)
Make each individual measure that comprises the measures group also stand-alone individual measures
David B. Hackney, M.D., FACR