Telling CMS What We Think About Changes in 2016 Proposed Rules

The following post was contributed by Geraldine McGinty, MD, MBA, FACR.

This week your Economics team at the ACR submitted detailed comments to the Centers for Medicare and Medicaid Services (CMS) on the agency’s proposed 2016 Medicare regulations.

On the Medicare Physician Fee schedule, we thanked CMS for their thoughtful approach to the Protecting Access to Medicare Act of 2014 (PAMA) law implementation that mandated appropriateness criteria use when ordering for advanced imaging for Medicare patients starting in 2017. We urged a delay in the enforcement of the XR29 regulation that will reduce payments starting in 2016 for CT scans performed on certain older units. We argued that the payment policy around this has not been fleshed out adequately and may result in unintended negative consequences for patients. We thanked CMS again for the decision to cover lung cancer screening with low dose CT but urged them to recognize the added intensity and work associated with providing this new service and increase the payment for it which they have proposed to set at the same level as a non-contrast chest CT. You can read the letter in full here.

We also submitted detailed comments to CMS on the Hospital Outpatient Prospective Payment (HOPPS) proposed Rule. Some might wonder why we need to pay attention to these payments which go to a hospital for the technical component of services performed in the hospital outpatient setting. Close attention is definitely warranted. Not only do these payment levels have a direct impact on the payments for advanced imaging in the independent office setting via the provisions of the Deficit Reduction Act, but they are also so complex that CMS welcomes input into how the code structures are developed and relies on our expert team at ACR. They don’t always take our advice but every summer our team meets with senior CMS staff on this topic and we know their input is highly valued.

The development of these comment letters, the research to replicate CMS’ assumptions and models and the face-to-face engagement with the agency has been a major priority for the staff and volunteers of the ACR’s Economics Commission this summer. Please join me in thanking them all for their dedication and expertise.

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