When the Centers for Medicare and Medicaid Services (CMS) released the proposed rule changes for the 2012 Medicare Physician Fee Schedule, the medical imaging community was up in arms about several changes made to the multiple procedural payment reduction (MPPR) rule. In the 2012 proposed fee schedule, CMS suggested a 50% MPPR to the professional component for CT, MR, and ultrasound services provided by one or more physicians in the same group practice furnishing services to the same patient, in the same session. While the American College of Radiology (ACR) successfully fought to have the policy removed or reduced—it was changed to 25%—CMS subsequently included a clause applying it to when one or more radiologists in the same group practice interpreted studies for Medicare patients receiving two or more CT, MR, or ultrasound studies on the same day, which the ACR eventually fought back as well.
With the release of the 2013 Medicare Physician Fee Schedule, many of those same issues have risen again: CMS has chosen to reinstate the 25% MPPR to the professional component. While it is still early in the process, members of the medical imaging community can expect a similar, aggressive response from the ACR that was on display last year.
“CMS maintains that there are efficiencies when one physician reads two different studies,” said Geraldine McGinty, MD, FACR, chair of the ACR Commission on Economics. “The ACR actually did a scientific study and published a paper last summer showing that there might be some very small efficiencies. Our paper showed that there were some very minimal efficiencies potentially on the pre- and post-service work, but nothing of any significance on the inter-service time.”
McGinty believes that any MPPR applied to the professional component represents a flawed policy and plans to help lead the charge to once again remove it from the proposed fee schedule. CMS released its proposal on July 6, 2012, and typically allows a 60-day review and comment period for members of the industry. The ACR will be thorough and diligent with its response.
“It’s a 700-page rule so we will take some time,” McGinty said. “Beyond the MPPR provisions, there’s a lot of language around the PQRS measures. We want to take our time to make sure that we understand those. There is a lot of language around telehealth, which, given that teleradiology is a big part of our world, we wanted to make absolutely sure that we understood. Our staff has been working hard on going into detail so that we can make sure that our response is as complete as possible.”
It will take time for the final version of the 2013 Medicare Physician Fee Schedule to come to light—the final rule will be released in November. Until then, the ACR will continue to mount its response to a policy that it feels is unjust and flawed, and will encourage its members to contact their representatives to have it changed.
“Last year, we were successful in getting CMS to reduce the MPPR on the professional side,” McGinty said. “It still wasn’t our ideal. We feel that any professional MPPR is unwarranted and inappropriate. We will certainly do our absolute best to convince CMS that this is a flawed policy.”
