CMS chose Halloween to issue a review copy of the 2015 Medicare Physician Fee Schedule (PFS) final rule, foreshadowing a 21.2% reduction in payment rates for all physicians beginning April Fool’s Day, and a few choice tricks for radiology on January 1.

In hard dollars, the conversion factor, based on Medicare’s sustainable growth rate (SGR) formula, will drop from $35.80 to $28.22. The cut would have kicked in New Year’s Day had not President Barack Obama signed the Protecting Access to Medicare Act of 2014, winning a temporary stay.

The American College of Radiology said it will convey radiologists’ specific concerns with various aspects of the new MPFS before the close of the 60-day comment period. To get more immediate reaction, RadiologyBusiness.com spoke with Geraldine McGinty MD, MBA, who practices at New York-Presbyterian Hospital and serves as chair of ACR’s commission on economics. A preliminary summary of the final rule has been posted on the ACR web site.

RadiologyBusiness.com: Let’s start with the bright spots. What does ACR like in the final rule?

McGinty: We’re happy that CMS is going to be paying for tomosynthesis. We think it’s a promising technology, and, as we said in our statement of this past summer, we’re not going to be able to fully understand how it should be used across the population unless it’s reimbursed. So we are very happy to see CMS reimbursing tomosynthesis.

The other thing we’re happy about is the new breast ultrasound values. There are two new breast ultrasound codes, the limited and the complete. Both are valued at higher than the current code. A little bit of a dark side there is that breast ultrasound is now being included among the services that are covered by the DRA cap. (The Deficit Reduction Act of 2005 said that, for advanced imaging, CMS would pay the lower of the Hospital Outpatient Prospective Payment System, or HOPPS, technical-component reimbursement for imaging.) We are now modeling that out to understand what the impact will be. We don’t have that done yet. But we’re happy with the higher values for breast ultrasound.  

The other bright spot is that CMS decided not to make the cost of the radiation vault indirect. The practice expense formula is complex, and CMS never pays us the entire cost, but they pay less of our cost for the indirect pool of expenses. So it was going to be a big negative if they transitioned the cost of the vault to the indirect expenses, and they decided to hold off on that for now.

RadiologyBusiness.com: Biggest disappointment?

Big time, the PACS issue. There’s been a very appropriate project to transition the practice expense inputs from film to digital. And CMS has decided that they haven’t gotten enough information—which, by the way, is not true. We’ve worked hard to give them inputs, and they’ve kind of ignored those. They’ve decided that they’re just going to use a desktop computer as a proxy for PACs expenses. That’s totally unrealistic. We’ve already met with them, we’ve convened a workgroup and we are going to be pushing back really actively on that.

RadiologyBusiness.com: Who besides radiologists are in that workgroup?

We’ve tapped into the IT community, the RBMA community, consultants. The RAND company has been working with us, doing a lot of modeling for us on the PACS expense base. We’re trying to make this as robust a process as possible.

RadiologyBusiness.com: It must be frustrating to repeatedly offer comments that are thoughtful, carefully considered, reasonable—and unheeded.

McGinty: Their response is, “We haven’t gotten invoices.” We’ve worked with them. We’ve talked to them about the fact that some of the ways that they think about pricing just simply don’t apply to PACs. You can’t buy a unit of PACS—you have to buy a PACS system. CMS likes to think of things in terms of “how many CCs of developer fluid go to develop a piece of film.” It’s not realistic to price PACs that way. They have to understand the structure of PACS. So we have assembled a great workgroup of experts. We are delighted to work with the agency; we understand this is challenging for them. But we’re not happy with the proxy that they’ve decided to use in the interim.

RadiologyBusiness.com: At a time when the government is trying to curb healthcare costs while maintaining care quality, this comes down as a fairly sweeping measure that could’ve been much worse. Correct?

McGinty: Yes, it could always be worse. And we’re always happy when the agency recognizes the value of what we do for our patients. It’s disappointing when they look at things in which people have made major investments, like PACS—things that have really improved quality of care through the ability to do remote readings and more efficient readings. It’s disappointing when they don’t see that. But we don’t get discouraged. Disappointments just make us want to work harder.

Click here to read ACR’s preliminary summary of the PFS and here to download the review copy of CMS’s 1,185-page final rule.