Radiology Leadership: Proposed Reimbursement Cuts “Arbitrary”

A new round of potential cuts to radiology reimbursement has many in the industry expressing anger and frustration. Radiology leaders have called the proposals “arbitrary” and “unfounded,” and all agree the reductions will negatively impact practice management and patient care.

CMS this week released its proposed Medicare Physician Fee Schedule for 2013, calling for a 4 percent to 19 percent drop in radiology reimbursement rates. The proposal would also extend a contentious policy that governs imaging conducted by a single physician during one patient encounter.

“The most important thing to remember is these are the latest in a series of arbitrary cuts to radiology reimbursement that started with provisions back in 2006,” said Geraldine McGinty, MD, chair of the American College of Radiology (ACR) Commission on Economics and the ACR Board of Chancellors. “We’ve long argued that CMS has flawed data, and they continue to single out radiology based on the perception that imaging is a growing market with run-away costs. That’s simply not the case. Imaging and the associated spending levels are back to early 2000s levels.”

According to the proposed rule, many radiology services would see reimbursement levels drop: 19 percent in radiation therapy centers, 15 percent in radiation oncology, 8 percent in diagnostic testing facilities, and 4 percent in nuclear medicine. These cuts would be reallocated as 7 percent reimbursement increases to family medicine physicians and other primary care providers.

The quality of patient care, particularly in outpatient radiation therapy centers, could decrease if these proposed reimbursement cuts take effect as-is, McGinty said. Many of these centers would likely close their doors, limiting patient access to this type of high-quality, cost-effective care.

The industry’s strongest outcry, however, stems from a measure to expand the current 25 percent multiple procedure payment reduction (MPPR) on provider services for CT, MRI, and ultrasound. Currently, the MPPR applies to imaging services rendered by the same physician to the same patient during the same encounter. The new proposal would extend the MPPR to other physicians within the same group practice who performed subsequent procedures in those same patient encounters.

If this proposal becomes permanent, it will have a chilling effect of how providers work together, said Paul Ellenbogen, MD, FACR, chair of the ACR Board of Chancellors.“These cuts discourage doctors from working as a team and pull the rug out from under the very physicians working to save these people’s lives,” he said in a written statement.

There’s also a chance expanding the MPPR will have a significant, negative impact on work flow, said Mike Mabry, executive director of the Radiology Business Management Association. It’s unclear whether smaller or more rural radiology practices would be able to effectively and efficiently change their billing strategies.

“Whether work flow will be potentially impacted is one of the questions we’re looking at,” he said. “And, we don’t know whether current coding and billing systems have the ability to regroup episodes of imaging care and say, ‘Yes, this is in the same session,’ or include certain modifiers and tell CMS ‘No, this isn’t the same session, and the discount doesn’t apply.’”

Although the public comment period has just begun, Mabry recommended radiology groups compile practice-specific data to show how the proposed reductions would detrimentally impact their activities. He predicted practices that treat more trauma or cancer patients who need more imaging studies, as well as rural practices, will be most adversely affected by the MPPR expansion.

According to McGinty, the ACR is preparing a detailed response to CMS’s proposed cuts to radiology reimbursement and will soon ask its members to join a national campaign to lobby against these potential reductions.

“We plan to launch a grassroots effort to ensure our Congressional representatives and CMS know how our members feel,” she said. “We will read through the 700-plus pages of text – we don’t expect everyone to read that – but we will make sure they understand how these proposals could potentially impact them and ask that they give their feedback to legislators.”

Mabry agreed that convincing CMS to forgo additional radiology reimbursement cuts will require an industry-wide collaboration.

“There’s no doubt this will be issue No. 1 for a lot of radiologists and radiology organizations,” he said. “It’s still early, and a lot of strategies are in their infancy, but as our arguments sharpen, we’ll reach out to our members and encourage them to tell CMS their own stories and how these reductions will directly impact their practices.”