Due to the Deficit Reduction Act (DRA) of 2005, the technical component (TC) reimbursement for many imaging services is capped at the lesser of the Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (HOPPS) payment rates. The MPFS outlines reimbursement for the TC, professional component (PC or 26 in the fee schedule), and global rates for services performed in the freestanding office setting. The HOPPS is the payment system that outlines reimbursement rates for the technical component of services performed in the hospital outpatient setting.
The 2014 HOPPS proposed rule includes a proposal to use FY 2011 cost data to establish payment rates for computed tomography (CT) and magnetic resonance imaging (MRI) services. This proposal would cut hospital outpatient payments for CT and MR studies by 18 to 38 percent. Due to the DRA cap, the payment reduction on the HOPPS side has an impact on the payment rates under the MPFS. Under the MPFS, the technical component payment rates for some CT studies will face an approximately 30 percent reduction and some MRI studies 16 percent reduction.
The 2014 MPFS proposed rule includes a variety of factors that impact the reimbursement rates for radiology and radiation oncology services in addition to the DRA. The ACR has developed tables that detail the impacts of the proposed rule on each specific CPT® code. Table 1 shows the 70,000 series of CPT codes and Table 2 shows non-70,000 series of CPT codes performed by radiologists. The tables display the current 2013 MPFS payment rates and the proposed 2014 payment rates, taking into consideration all of the various factors that influence the reimbursement rates including, but not limited to the DRA cap , utilization rate and interest rate assumptions.
View Table 1 that shows the impacts for the 70,000 series CPT codes
View Table 2 that shows the impacts for the non-70,000 series CPT codes
Read the 2014 Medicare Physician Fee Schedule Proposed Rule Summary
The ACR has met with CMS staff on the use of the 2011 cost data and continues to fight the HOPPS proposal and its impact on the Physician Fee Schedule. The ACR will be submitting comment letters to CMS on the MPFS and HOPPS proposed rules that will address all issues impacting radiology and radiation oncology services.
Additionally, in an effort to assuage the overall impact of severe cuts to radiology reimbursement and ensure a smooth transition to a new physician payment system, the ACR recently began working with a multitude of other national medical professional societies on a data transparency and reimbursement dampening policy. In addition to requiring more robust disclosure of analytic methodologies used by CMS in justification of reimbursement cuts, the dampening policy is intended to limit the total amount a specific procedural code could be reduced by CMS in a given year. Although a nascent policy effort, greater data transparency will ensure proposed reimbursement reductions are substantiated by sound analyses, while the dampening policy ensures that physicians are not overburdened by annual double digit payment cuts.