Proposed Cuts Lead to Radiology Practice Self-Analysis

When CMS released its 2013 proposed Medicare payment cuts this month, no one in radiology was particularly surprised. Industry experts knew radiology settings and providers faced slashed reimbursement rates, and it’s now time for practices to assess just how affected they might be.

In the fee schedule, set for Jan. 1, 2013, implementation, CMS retained its proposed multiple procedure payment reduction (MPPR) of 25 percent to the professional component (PC) for CT, MRI, and ultrasound imaging conducted by one or more providers in the same practice on the same patient, during the same session, on the same day. The Medicare proposed cuts will also decrease overall payments to radiation therapy centers by 9 percent and reduce payments to radiation oncology providers by 7 percent.

Overall reaction, said Maurine S. Dennis, senior director of economics and health policy at the American College of Radiology, is that these proposed reductions are both arbitrary and complicated. The MPPR cut is creating significant angst, she said.

“It’s a cut - a cut to the professional component, so it’s real money out of our providers’ pockets,” she said. “The proposal deals a lot with subspecialists, and it’s complex. It’s going to take time to figure out how everything will shake out.”

The looming 25 percent MPPR cut isn’t the only problem, however, said Mike Mabry, executive director of the Radiology Business Management Association. CMS has also yet to publish any information or guidance about the new coding modifier it plans to implement for same-day, same-provider services. Currently, your coders use the -59 modifier to identify procedures done on the same day that are distinct from all others performed.

In addition, the agency has not released a definition for what it considers to be same-session, leaving practices to determine for themselves how best to process this type of claim. The best course of action, Mabry said, is for practices to conduct a self-assessment of how at-risk they are for MPPR PC payment cuts.

Practices that provide a higher level of tertiary care or other advanced diagnostic imaging services should conduct the most involved analyses of their same-day, same-session services. These settings, he said, will be the most vulnerable to the MPPR PC reduction and will feel the greatest impact on their bottom line.

“Individual practices should identify scenarios where the MPPR PC reduction and the new modifier could apply,” he said. “They’ll need to reach out to their billing system vendors to determine how those entities will respond to these cuts and changes in modifiers.”

Be sure to ask, Mabry advised, whether your billing vendor has designed a system or procedure that will handle this new modifier - when it is published - or if you will be required to manually process these claims yourself until an automated system becomes available.

Despite the reimbursement cuts, however, industry experts do not foresee any tangible impact on patient care, ACR’s Dennis said.

“Our doctors will do the work no matter what. They’ll be mad about it, but it’s to their credit that patients will get the care they need,” she said. “But it’s a double-edged sword because CMS looks at what the doctors will do and says that these reductions won’t affect access to care. Meanwhile, our colleagues are heavily impacted.”

In fact, she said, radiologists could begin to follow the growing trend in cardiology where more providers are shuttering their private practices and returning to hospital employment.

However, the door is still open, Dennis said, for more discussion at the legislative level. While the ACR plans to issue guidance in the coming weeks on how to face these reimbursement reductions, it will also work with political allies on Capitol Hill to determine whether it is possible to minimize the effect of these payment cuts on radiology.

“We’re doing work on the legislative side where we will get more bang for our buck,” she said. “We now know where CMS stands once again, so the focus is going to be on capitalizing the healthcare services our patients need.”