ACR to Comment on 2006 Medicare Physician Fee Schedule Proposed Rule
The ACR currently is analyzing the 2006 Medicare Physician Fee Schedule proposed rule (Federal Register, Monday, August 8) and its impact on Radiology.
Of note, CMS proposes to reduce the technical component payment for multiple imaging services performed on contiguous body parts. Eleven families (ie ultrasound, CT, CTA, MRI and MRA) will be subjected to the proposed payment reductions. Accordingly, when multiple procedures within the same family are performed in the same session, the highest value procedure gets paid at 100%, and 50% for any additional procedure. This proposed reduction mirrors the policy proposed under the Medicare hospital outpatient prospective payment system. The proposed reduction is based on the assumption that there are economies of scale in the technical component when procedures in the same family are performed in the same session. The ACR does not agree with these assumptions and will provide extensive comments to CMS addressing the College's concerns.
CMS also proposes to classify diagnostic and therapeutic nuclear medicine procedures as designated health services, making them subject to the physician self-referral (Stark) prohibitions. The ACR had advised CMS that diagnostic and therapeutic nuclear medicine services are part of radiology and should be incorporated into the definition of "radiology and certain other imaging services," already subject to physician self-referral prohibitions.
The College will submit its final comments to the Centers for Medicare and Medicaid Services before the comment deadline September 30. See the Sept-Oct 2005 ACR Radiology Coding SourceTM for a copy of the ACR's detailed comments to CMS on the 2006 MPFS proposed rule.
