The Health Care Financing Administration (HCFA) has proposed ambulatory patient classification (APC) reimbursement policy for hospital-based outpatient procedures that sets standard, equal reimbursement fees for imaging procedures whether or not contrast media are used.

With respect to health care’s current climate of cost containment, HCFA’s proposed APCs have raised troubling implications for patient care. Some observers are concerned that physicians may be encouraged to perform imaging procedures without contrast-a more profitable procedure in light of the APC streamlined reimbursement schedule-compromising the appropriateness of care.

To address this issue, the Medical Imaging Contrast Agents Association (MICAA) was formed. According to Jack Slosky, PhD, the director of health economics and professional relations in the medical imaging division of a major pharmaceuticals supplier and co-chair of the MICAA task force on the APCs, the need for single-voice advocacy on reimbursement and coverage issues regarding contrast agents and contrast-enhanced procedures was recognized for many years. HCFA’s proposed cuts to reimbursement catalyzed the formation of a committee and MICAA was created on March 8, 1999, at the American College of Cardiology convention in New Orleans. Even before MICAA was formed, Slosky says that an ad hoc reimbursement committee had been designated by the contrast-agent industry to ensure that joint comments would be submitted to HCFA before the March 9, 1999 deadline. When HCFA pushed the deadline for comments to June 30, 1999, in order to give the health care community more time to prepare data and gain a better understanding of the proposal, MICAA mobilized to produce complex, in-depth analyses of the implications of HCFA’s proposed APCs.

Gordon Schatz of Reed, Smith, Shaw & McClay, who serves as MICAA’s attorney, believes it is important that HCFA not “create financial disincentives for hospitals to use existing contrast agents and, even more important, the newer technology contrast agents that are just coming into clinical practice now.” Schatz described MICAA’s three-part plan for responding to the proposed APCs. The first step was to get data on hospital billing and current charges for contrast-enhanced procedures; educate the association on the issues; and extensively analyze that data. The second step, well under way, is to draft final comments, based on the compiled data, regarding the effect of HCFA’s proposed APCs on imaging procedures and, ultimately, patient care. The final step will be for the committee to share its comments with physician societies and hospital groups.

According to Schatz, MICAA will continue to work with government agencies to ensure advocacy for contrast-based procedures after submitting comments on HCFA’s proposed APCs. “There have been significant developments dealing with FDA approval of new contrast agents and other reimbursement issues, not only with the proposed APCs, but with physician payment under the resource-based relative value scale.”

Slosky believes that the health care industry must take a tripartite approach to health care regulation. “We need to be proactive, identifying issues as they emerge, and suggesting approaches to these issues to HCFA as soon as possible,” Slosky says. “We need to partner with societies, physicians, providers, HCFA, and insurers [in order to approach these issues as a unified front]. And we need to be patient, as changing and forming reimbursement policies takes time.”

Schatz urges those in the health care industry who want to get involved to communicate with their specialty societies. “But that should not preclude physicians pulling data, doing their own analyses, and sending those out with recommendations to HCFA,” Schatz says, “because that can be very valuable and our system is predicated on people taking responsibility for talking to the government. So doctors who want to write letters should. But I think that what are often called letter-writing campaigns of identical suggestions are no longer influential at HCFA.”

While data are necessary to prove points, substantiated recommendations are important in dealing with HCFA. “If doctors are interested in developing their thoughts or sharing that information, I know MICAA is very interested in working with individuals and physician groups,” Schatz states.


Leslie Farnsworth is a contributing writer for Decisions in Axis Imaging News.