The Centers for Medicare and Medicaid Services (CMS) in 2019 finalized a sweeping revaluation of all outpatient evaluation and management (E/M) codes for implementation in 2021; E/M codes account for roughly 25% of allowed charges under the Medicare Physician Fee Schedule (MPFS). This revaluation, combined with the addition of a CMS-generated add-on code for complex care, meant many physician and non-physician clinicians — such as radiologists, who infrequently, if ever, bill E/M — were facing significant Medicare reimbursement reductions because of statutorily required budget neutrality (meaning increases to one component requires proportional reductions to other components).
The American College of Radiology® (ACR®) acted quickly to form a coalition of impacted specialty physician and non-physician clinician associations. The ACR-led coalition began advocating in early 2020 for congressional relief from these cuts. That December, Congress responded to the coalition’s joint advocacy by adding an additional 3.75% positive update to the MPFS conversion factor (CF) (a national dollar number applicable to the entire MPFS) for 2021 and delaying the implementation of the CMS-generated add-on code for three years. These actions mitigated the Medicare payment reductions to radiology by roughly two thirds. The addition of the 3.75% increase to the Medicare CF allowed our coalition to grow to include primary care clinicians and other clinicians who frequently bill E/M.
In 2021 the coalition remained united and urged Congress to again supplement the MPFS via a positive adjustment to the CF in 2022. Congress responded with an additional 3% to the CF for 2022.
As 2022 draws to a close, the ACR-led coalition continues to work together to urge Congress to add an additional 4.5% to the MPFS CF for 2023, which would encompass both the expiring 3% and the budget neutrality adjustment in the 2023 MPFS final rule; this would essentially restore the MPFS CF to 2022 levels.
Most recently, more than 100 physician and non-physician clinical organizations sent a letter to House and Senate leadership stressing the importance of congressional action prior to the end of the year to eliminate the entirety of the impending 4.5% reduction.
To echo the most recent coalition letter, the ACR Radiology Advocacy Network (RAN) has issued a call to action, asking ACR members to contact their member of Congress and Senators and urge them to #stopthefullcut.
For more information about ACR’s actions to fight Medicare reimbursement cuts, please contact Rebecca Spangler, ACR Senior Government Affairs Director.