ACR to CMS: Remove Professional Component Multiple Procedure Payment Reduction from Medicare Physician Fee Schedule Rule

ACR to CMS: Remove Professional Component Multiple Procedure Payment Reduction from Medicare Physician Fee Schedule Rule

In comments on the 2012 Medicare Physician Fee Schedule Proposed Rule, the American College of Radiology told the Centers for Medicare and Medicaid Services (CMS) that a proposed multiple procedure payment reduction (MPPR) to the professional component of imaging is scientifically unfounded, based on flawed assumptions and may limit patients’ ability to receive efficient care.

The ACR comment letter highlighted recent purported statements from CMS Administrator Donald Berwick, MD, during his visit to a radiologist’s imaging facility regarding efficiencies in imaging interpretation. Dr. Berwick’s statements further call into question the validity of such a reduction. Therefore, ACR called on CMS to exclude the MPPR from the Medicare Final Rule due out later this year.

In its Proposed Rule for 2012, CMS called for a multiple procedure payment reduction (MPPR) of 50 percent to the “professional component” of CT, MRI and ultrasound services administered to the same patient, on the same day, in the same setting. This unprecedented step would slash reimbursement for physician interpretation and diagnosis. Cuts have previously been applied only to the "technical component," or overhead costs of providing exams.

Although potential efficiencies in physician work may exist when multiple services are provided to the same patient during the same session, a recent study a href="http://www.jacr.org/article/S1546-1440">http://www.jacr.org/article/S1546-1440(11)00331-0/abstract> published in JACR shows that these are highly variable and are, at most, only one-tenth of what policy makers contend.

The ACR also urged CMS to reconsider additional bundling of payments for many imaging procedures commonly performed in parallel.

Please read the ACR comment letter a href="http://www.acr.org/SecondaryMainMenuCategories/NewsPublications/FeaturedCategories/CurrentACRNews/archive/ACR-Comment-to-CMS-2012-on-MPFS-Rule.aspx">http://www.acr.org/SecondaryMainMenuCategories/NewsPublications/Fea...; to CMS on 2012 Proposed Rule.


Healthcare Organizations Echo ACR Opposition to Imaging MPPR in Medicare Rule

An array of healthcare organizations, including the American Medical Association, Association of Community Cancer Centers, Healthcare Business Management Association, Medical Imaging Technology Alliance and Medical Device Manufacturers Association recently sent comments to the Centers for Medicare and Medicaid Services (CMS) stating that a multiple procedure payment reduction (MPPR) a href="http://www.acr.org/HomePageCategories/News/ACRNewsCenter/2012-Proposed-Cuts.aspx">http://www.acr.org/HomePageCategories/News/ACRNewsCenter/2012-Propo...; to the “professional component” of imaging exams is not scientifically supported, redundant and unwarranted.

In its Proposed Medicare Fee Schedule Rule for 2012 a href="http://www.gpo.gov/fdsys/pkg/FR-2011-07-19/pdf/2011-16972.pdf">http://www.gpo.gov/fdsys/pkg/FR-2011-07-19/pdf/2011-16972.pdf>; , CMS called for a multiple procedure payment reduction (MPPR) of 50 percent to the “professional component” of CT, MRI and ultrasound services administered to the same patient, on the same day, in the same setting. This would slash the reimbursement for physician interpretation and diagnosis. Cuts have previously been applied only to the "technical component," or overhead costs of providing exams.

Many of the organizations questioned CMS’ contention that there are similar efficiencies in the professional component of imaging to that of many surgeries and highlighted a recent study a href="http://www.jacr.org/article/S1546-1440">http://www.jacr.org/article/S1546-1440(11)00331-0/abstract> published in JACR which shows that any efficiencies that exist are highly variable and exponentially less than CMS contends.

Please see the passages below from various comment letters:

“[CMS] oversimplifies related GAO and MedPAC recommendations, misconstrues the findings of the RUC, overlooks relevant CMS data and results in a proposal that is likely to increase costs to Medicare and its beneficiaries…” – American Medical Association

“We believe the proposed expansion of the MPPR is not justified and could harm access to appropriate cancer care” – Association of Community Cancer Centers

“These findings clearly illustrate that there is an extreme disconnect between CMS’ policy proposal and actual medical practice.” – Healthcare Business Management Association


Please click the links below to read the comments to CMS from each of the following organizations:

American Medical Association a href="http://www.ama-assn.org/resources/doc/washington/2012-physician-fee-schedule-nprm.pdf">http://www.ama-assn.org/resources/doc/washington/2012-physician-fee...;

Association of Community Cancer Centers a href="http://www.accc-cancer.org/advocacy/pdf/2012Proposed%20PFScomments.pdf">http://www.accc-cancer.org/advocacy/pdf/2012Proposed%20PFScomments....;

Healthcare Business Management Association a href="http://www.hbma.org/uploads/content_files/2012_Physician_Fee_Schedule___FINAL_COMMENTS.pdf">http://www.hbma.org/uploads/content_files/2012_Physician_Fee_Schedu...;


To speak with an ACR spokesperson, please contact Shawn Farley at 703.648.8936 or PR@acr.org