The Medical Imaging & Technology Alliance (MITA) – the leading trade association representing manufacturers of medical imaging equipment, radiopharmaceuticals, contrast media, and focused ultrasound therapeutic devices – expressed concern for the significant payment cuts included in the Centers for Medicare and Medicaid Services’ (CMS) proposed payment policies for the Physician Fee Schedule (PFS) and Part B Rules for calendar year (CY) 2023 in comments submitted to the Agency.
“While the full effect may be difficult to estimate, the cumulative cuts proposed through a conversion factor rate adjustment, budget neutrality requirements, and clinical labor pricing changes will surely impact patients’ ability to access the care they need,” said Patrick Hope, executive director of MITA. “In addition to the proposed payment cuts, care providers are also navigating compounding economic pressures, including record inflation, a labor shortage, and the ongoing long-term impact of the COVID-19 public health emergency.”
In addition to expressing concern for Medicare’s proposed payment cuts, MITA’s letter also:
- Suggests that when evaluating high-value, underutilized services, CMS should consider policies to promote access and meet goals for adherence to screening exams for Medicare beneficiaries;
- Recommends that as CMS develops the discarded drug refund, the Agency honor Congress’ exclusion in statute for radiopharmaceuticals and imaging agents because they are typically prepared in a patient-ready dose;
- Asks that CMS confirm it does not have the legal authority to package radiopharmaceuticals and treat them as incident to supplies. Instead, MITA supports continuation of current policy that radiopharmaceuticals are subject to separate payment;
- Endorses an expansion of colorectal cancer screening coverage to include CT colonography to align with updated recommendations from the United States Preventive Services Task Force (USPSTF);
- Opposes changes to the Medicare Economic Index until more data and stakeholder input has been collected;
- Expresses support for the Agency’s consideration of alternative methodologies to appropriately reimburse providers for innovative technologies and artificial intelligence (AI) as well as willingness to continue to work with CMS in the development of appropriate payment policies for AI technologies; and
- Restates support for development and implementation of an appropriate use criteria policy that would help to ensure that patients get the right scan at the right time.
“We urge CMS to take whatever steps it has within its authority to mitigate these payment cuts—including reducing the impact or delaying implementation—and to work with Congress on policies that will ensure the ongoing stability of the PFS,” Hope concluded.
To read MITA’s full comments, click here.