The ACR team met this week with CMS to discuss the Hospital Outpatient Prospective Payment System (HOPPS). Our team, led by Jim Rawson, M.D., chair of our HOPPS committee, also included me, Pam Kassing, Katie Keysor and two talented consultants from the Moran Company, Rachel Feldman and Mark Desmarais.
Our first task was to help CMS in their task of assigning the new 2014 radiology CPT codes to the proper Ambulatory Payment Classification (APC) so they are paid properly in the hospital outpatient setting. The new codes describe breast interventions, abscess drainage catheter placement, vascular embolization and vascular stent placement. These code families are complex bundled combinations of existing codes, so the American College of Radiology’s clinical input is crucial. Our consultants help us evaluate the historical claims data, calculating the proper geometric mean costs to support our APC recommendations.
Our second task was to again express our grave concerns over the application of new CT and MR cost center data to the Outpatient Prospective Payment System, since this will secondarily impact physician payments in the Medicare Physician Fee Schedule thanks to the Deficit Reduction Act. We emphasized that the hospital cost data for these centers is woefully inadequate and not worthy of application in any setting.
Overall, the meeting was positive and I am optimistic that our APC recommendations will be accepted. I am also hopeful that our comments on the CT/MR cost centers were understood and will convince them to abandon this flawed proposal. We expect to know how CMS will rule on these concerns towards the end of November. My thanks to the whole team.
Author – Ezequiel Silva, M.D., co-chair Commission on Economics
Well, the government is back in business — time to renew and re-engage with politics in the 113th Congress and radiology.
As you may know, the House Energy and Commerce Committee has passed a Sustainable Growth Rate (SGR) proposal. Within the proposal is language addressing Multiple Procedure Payment Reduction (MPPR) and Clinical Decision Support (CDS). The U.S. Health and Human Services secretary would be required to present the data used to justify MPPR reductions (we cannot find any). CDS impact would be required to be studied. Significantly, radiology was the only specialty to get language in the proposal thanks to the hard work of our government relations team at the American College of Radiology. This represents a huge win for us. The next goal is to get the other two committees of jurisdiction, the House Ways and Means and Senate Finance committees, to improve and adopt the language.
Even if we are successful in including our legislative priorities in Committee language, the politics of SGR are dynamic. In the beginning of the year there was considerable momentum to pass a reform bill given that the U.S. Government Accountability Office scoring was a relatively low $138 billion. The score has subsequently been revised slightly upward. With all the other Washington distractions, the SGR momentum may be losing some steam so it is unclear if we will see a reform bill or a last minute fix to avoid another SGR cliff looming in January 2014. Stay tuned!
Author – Howard B. Fleishon, M.D., MMM, FACR
I hope that by now you are familiar with the Imaging 3.0 campaign. If you’re not, please check out our website at http://www.acr.org/Advocacy/Economics-Health-Policy/Imaging-3. There you will find case studies, scholarly articles and a flowchart that you can use to analyze the challenges and opportunities for your practice.
The American College of Radiology’s economics and government relations teams are working hard to make sure that the principles of Imaging 3.0 are incentivized in payment policy. As we do that, however, it is important to be clear on what we are already getting paid for under the descriptions of work contained in the Medicare physician fee schedule.
Medicare divides physician work into three categories: pre-service, intra-service and post-service work. The interpretation of the images and the generation of a report constitutes the intra-service work. For most radiology services there are important components of the service we provide that are considered pre- and post-service work. Protocoling the exam, counseling the patient about contrast allergies or discussing the indications for the examination with the technologist are pre-service work. Finalizing the report and the all important communication with referring physician colleagues (when it occurs) are contained within the existing definition of post-service work. All of the aforementioned elements are included for Medicare reimbursement as it currently stands.
As we look for ways to recognize the many ways that radiologists deliver value in the new world of health care, it is critical that we understand what we are already getting paid for albeit at less than optimal rates for many services.