In a 38-page letter to CMS, ACR submitted wide-ranging comments on the proposed 2015 Medicare Physician Fee Schedule rule, from practice expense inputs to account for the film-to-digital migration to expediting the implementation of new and revalued codes.

More than 15 pages of the letter, however, were devoted to providing input on the minutia associated with the agency’s many quality programs that will underpin the movement to value-based payment in the Medicare system

Although the AMA Relative Value Update Committee (RUC) recommended replacing film supplies and equipment with PACS-specific supplies and equipment for 604 existing imaging codes, CMS proposes using minutes on a desktop computer as a proxy for the PACS workstation as a direct expense because it did not receive supporting invoices for the PACS expenses.

Stating that the use of the desktop computer proxy for PACS greatly underestimates the expenses incurred by physicians, the ACR requests a one-year delay on the action while it works with CMS to identify the proper digital practice-expense inputs and source the appropriate invoices.

Using the example of CPT code 76377—3D rendering with interpretation and reporting of CT, MRI, ultrasound; requiring image post processing on an independent workstation—the ACR points out that the code suffers a 45.7% reduction when the film-based inputs are removed, but gains just 1.7% when the desktop computer is substituted for the high-tech hardware and software that comprise PACS and advanced-visualization workstations.

The RUC also recommended revisions to clinical labor times to reflect the migration from film to digital imaging, which the ACR supports as well, but CMS proposes applying those retroactively to all imaging codes, even though the CMS database does not include the level of detail necessary to arrive at specific clinical labor times.

“Our goal would be to collaborate on recommendations in time for public comment during the CY 2016 notice of proposed rule making (NPRM); and that CMS update the PACS-related clinical tasks in new imaging codes going forward, but not attempt to retroactively update these inputs across all imaging codes until task specific clinical labor time inputs are readily available,” wrote William Thorwarth, MD, CEO, ACR.

Other specific requests in ACR’s comment letter to CMS include:

• Implement modifications recommended by the AMA in CPT/RUC workflow to enable both adequate time to review new codes and timely implementation of those codes (thereby simplifying billing by eliminated temporary G codes).

• Offer an expedited online enrollment process for locum physicians to minimize payment delays if CMS and commercial insurers require that practices enroll these temporary physicians as proposed in the rule.

• Maintain code 36215 ((Selective catheter placement, arterial system; each first order thoracic or brachiocephalic branch, within a vascular family) until three years of utilization data is available rather than bundle it with the other cervicocerebral angiography codes so that the typical vignette and dominant specialty can be determined.

• Maintain the payment rates for digital mammography rather than reduce the technical component for digital mammography to the rate of analog mammography.

• Reconsider the proposed radiation treatment vault policy change and delay any fdinal decision until after the radiation oncology coding changes are implemented.

• Review the RBMA survey data and increase the maintenance assumption in the equipment cost formula to 10% for all imaging modalities and 15% for mammography.