HPC Corner: A Storm is Brewing Once Again

HPC Corner: A Storm is Brewing Once Again
Greg Nicola, MD, FACR

Some of the ASNR membership may be unaware of the last 9 years of tumult a group of hardworking volunteers serving on the ASNR economics committee have successfully endured. It began in the fall of 2009 when the Centers for Medicare and Medicaid Services (CMS) and the Relative Value Scale Update Committee (RUC) pointed cross hairs at our set of Current procedure Terminology codes (CPT) valued prior to this date via a separate, but parallel process from codes in most of the rest of medicine. Virtually all the common procedures we as neuroradiologists perform had not received an official stamp of approval by the RUC, the so called “RUC Reviewed” label, but instead were listed in the CMS database as having time sources and valuations of “CMS Other.” Over the next 9 years, the ASNR team painstakingly brought each and every diagnostic neuroradiology CPT code in front of the RUC, presenting survey data from our members which evaluate relative work times and describe the type of work we do as radiologists. The RUC uses this survey data to assign relative value units (RVUs), placing our codes on a relative scale compared to the rest of the house of medicine. These RVUs are then used by CMS and commercial payers to calculate a payment for such services. Many ASNR members are unaware of this 9-year battle because the team was so successful in maintaining our professional component reimbursement. Now that all our procedures have the official “RUC Reviewed” label, one might think that radiology would be out of the valuation cross hairs. This is not the case. A congressional mandate from the Protecting Access to Medicare Act of 2014 required validation of RUC methodology, and two independent organizations (RAND Corporation and Urban Institute) were granted governmental funding to carry out the process1. Both Rand and Urban institute designed validation projects that looked at absolute measures of time, and cherry-picked codes in biased fashion, ignoring the concept of relativity so important in the RUC process. Several of our RUC reviewed CPT codes were interrogated by this methodology, and subsequently deemed potentially misvalued. Since publication of these results, little has been made of their validity, until the 2019 Proposed Rule for the Medicare Physician Fee Schedule in which unknown stakeholders used these results to prompt CMS for potential revaluation of the codes in question2. So here we go again. Fortunately, the ASNR economics team has never let down its guard and continues to recruit skilled volunteers to stay in the trenches defending proper reimbursement for the vital services we provide our patients. We aren’t alone in this battle; our members play a vital role alongside us. It is your survey data telling us what you do, and how long it takes when you are diligently working to improve your patients’ health. Stay tuned.

References

  1. Authenticated U.S. Government Information. 113th Congress: Protecting Access to Medicare Act. https://www.congress.gov/113/plaws/publ93/PLAW-113publ93.pdf. Published 2014. Accessed 2018.
  2. Centers for Medicare and Medicaid Services. 2019 Medicare Physician Fee Schedule Proposed Rule. https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/PFS-Federal-Regulation-Notices-Items/CMS-1693-P.html. Published July 27, 2018. Accessed 2018.

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