The list of entities with imaging in their crosshairs goes on and on, but when it comes to eroding reimbursement and enhancing oversight, the current primary culprits are CMS and Congress, according to Maurine Spillman-Dennis, MBA, MPH, director of economics and government relations for the ACR®. In the “ACR Economic Update” presented on September 28 at the 2010 RBMA Fall Educational Conference in Austin, Texas, Spillman-Dennis and her colleague, Judith Burleson, MHSA, ACR director of metrics, outline some of the current challenges and opportunities facing the profession. Although the former outnumber the latter, the news isn’t all bad.
The Spillman-Dennis portion of the presentation focuses on recent and upcoming changes in imaging reimbursement—and how the ACR is working to combat them, where possible. She begins with a look at the 2011 proposed (now final) Medicare Physician Fee Schedule (MPFS), which reduces the physician-payment conversion factor by 6.1% in 2011, adding to the 21.2% scheduled reduction that was delayed by Congress, over the summer, until November 30.
Spillman-Dennis adds that it’s still difficult to tell whether action will be taken at that time; if Congress fails to delay the cuts or create a permanent change in the formula for the sustainable growth rate (SGR), imaging could be looking at reimbursement cuts on top of reimbursement cuts.
The ACR also is concerned that the 2011 MPFS might undervalue certain imaging-procedure codes. “One of the big misperceptions out there is that imaging services are overpriced,” Spillman-Dennis explains. “That puts codes under the microscope—we have to justify maintaining their current value.” She notes that the DHHS secretary is likely to zero in on codes with the fastest growth, codes that pertain to new technologies or services, codes that tend to correspond with low RVUs, and codes not reviewed since the early 1990s.
She adds, however, that the DHHS secretary also has the license to review any other codes, as the DHHS deems that review appropriate. “Basically, this is the whole fee schedule,” she concludes. “The days of review every five years are done.”
The Patient Protection and Affordable Care Act (PPACA) mandated changing the equipment-utilization rate (for diagnostic equipment priced at over $1 million) to 75%; in the 2011 proposed MPFS, CMS issued a few clarifications of this change. First, the rate will also affect CT angiography (CTA) and MR angiography; second, the 75% rate will supersede the original CMS plan to increase the rate to 90%.
The 2011 MPFS also proposes expanding the multiple-procedure reduction from 25% to 50% for the technical component of CT, MRI, and ultrasound—even if the body parts imaged are noncontiguous. The change applies to 11 families of codes, and CMS proposes adding cardiac CT and coronary CTA to these.
In an ACR analysis of the potential impact of these changes, neuroradiologists and providers of portable radiography actually stand to benefit, while general radiology could suffer a 12% overall payment reduction, and IDTFs could see an even more onerous 20% reduction in reimbursement. When the ACR met with CMS to discuss the multiple-procedure reduction, the agency seemed to suggest that while the change might not be fair, Congress was just as likely to implement it down the line, Spillman-Dennis says. “We talked to them about how we’re in the process of bundling ourselves,” she adds. “The back and forth was cordial, and they seemed to get it, but who knows?”
Many CMS calculations are based on the Physician Practice Information Survey, an update of the AMA’s Socioeconomic Monitoring System. The ACR paid around $75,000 to participate in this year’s survey, and the results weren’t promising: “We got hosed,” Spillman-Dennis says. According to the survey, radiologists’ practice expenses will decline by 33% next year, and that figure is what CMS will use in its allowances regarding practice expenses.
The ACR’s stance is that the survey wasn’t an accurate representation of radiology because its 56 respondents were primarily hospital-based radiologists—without any practice expenses whatsoever. “We complained about the transparency and lack of access to data, and we asked them to delay implementation,” Spillman-Dennis says. In the face of these complaints, CMS agreed to transition in the new practice-expense calculation over four years. “Still,” Spillman-Dennis says, “it’s a hit.”
Congress Takes a Bite