January 08, 2016

ACR Submits Comments on the 2016 Medicare Physician Fee Schedule Final Rule

The timing of Medicare’s planned implementation of mandated Appropriate Use Criteria (AUC) for medical imaging orders tops the list of concerns about the 2016 Medicare Physician Fee Schedule (MPFS) Final Rule covered in comments from the American College of Radiology (ACR) submitted to the Centers for Medicare and Medicaid Services (CMS) on Dec. 23.

The College urged CMS to maintain the Jan. 1, 2017, implementation of mandated use of Appropriate Use Criteria (AUC) for advanced diagnostic imaging services, as opposed to a phase-in approach beginning at some point after Jan. 1, 2017. The ACR is prepared to execute its AUC program and can assist CMS in achieving its goal of timely implementation.

The ACR thanked CMS for their efforts in working with the College to ensure appropriate practice expense inputs for digital imaging services in place of the desktop computer proxy that was implemented for calendar year 2015. Though the increase is an improvement, the ACR also believes the cost of the professional workstation should be considered a direct expense within the practice expense formula. The ACR indicated that we will work with CMS to identify the codes that require a professional PACS workstation and to define the appropriate number of minutes used relative to existing physician work time and clinical labor tasks.

The College disagreed with CMS’s decision to set the valuation of low-dose lung computed tomography (LDCT) for lung cancer screening at the same level as a standard CT of the thorax without contrast. We expressed concern that providers may not be able to offer this life-saving service to Medicare beneficiaries if LDCT reimbursement proves inadequate. We also pointed to what we believe are technical errors in the relative value unit (RVU) file published with the Medicare Physician Fee Schedule (MPFS).

The ACR also commented on a variety of issues raised by CMS including final and interim final RVUs for new and revised CPT codes, equipment maintenance costs, changes for CT under the Protecting Access to Medicare Act of 2014 (PAMA), target for relative value adjustments for misvalued services, practice expense refinements, and quality provisions of the proposed rule.

For questions on the 2016 MPFS final rule or the ACR comments on the rule, please contact Katie Keysor at kkeysor@acr.org.