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.
As the American College of Radiology (ACR) submitted comment letters on the Centers for Medicare and Medicaid Services (CMS) proposed rules for 2014, there was much consternation swirling around the topic of potential cuts to the codes for image-guided breast biopsy. It is worth reviewing how code values are developed and at what point they become public.
The American Medical Association’s (AMA) Relative Value Update Committee (RUC) reviews codes created or modified by the CPT Editorial Panel. The RUC sends its recommendations for code values to CMS. CMS is the final arbiter and the code values are only made public when CMS has weighed in. In the majority of cases CMS accepts the RUC’s recommendations, but increasingly CMS will make changes to the values, often downward.
A new set of bundled codes for image-guided breast biopsy was created by the CPT Editorial Panel CMS’ request last year. Those codes were reviewed by the RUC and recommended values sent to CMS. CMS will publish the values for these codes with the Final Rule around Oct. 31, 2013. Until that happens the RUC’s recommended values are confidential. If we breach that confidentiality, ACR’s continued participation in the RUC process will be jeopardized.
If, when the codes are published we feel that the values do not accurately reflect the effort involved (or will cause access to these services to be denied to our patients) we will have the opportunity to appeal the values as they are considered interim for one year. Watch this space!
The work of the American College of Radiology (ACR) advocacy and economics teams is critical to ensuring the future of our specialty and delivery of imaging care to our patients. We all have a stake in how effective we are as a specialty in the legislative and political arenas. The success of our practices and departments depend on it.
Keeping you informed is a priority for us at the ACR. With the pace of change, news often needs to get to you faster and in a format that encourages comments and discussion.
ACR staff has developed this blog to facilitate communication and highlight critical issues. We will only focus on advocacy and economics. While we might introduce items and moderate discussion, we look forward to contributions from the many gifted physician volunteers and staff who are working on the front lines. Most importantly, this blog will be a forum for the wider radiology community.
This is a new process for us. Help us by posting comments and distributing to your colleagues. And thank you for support.