The American College of Radiology (ACR) has prepared a detailed analysis of proposed rule changes to the Medicare Physician Fee Schedule in calendar year 2017. The proposed rule has a 60-day comment period closing on Sept. 6, 2016, and the ACR will provide detailed comments. If finalized, the rule changes will be effective Jan. 1, 2017.
The ACR is pleased with several aspects of the rule, including valuation of mammography with computer-aided diagnosis (CAD), the inclusion of a professional PACS workstation in the valuation of over 400 radiology services, and the proposed implementation of the Congressionally mandated professional component multiple procedure payment reduction (MPPR) reduction from 25 percent to 5 percent beginning on Jan. 1, 2017.
ACR physicians and staff held numerous conference calls and meetings with the Centers for Medicare & Medicaid Services (CMS) on the topic of the Appropriate Use Criteria (AUC) mandate implementation, advocating for comprehensive implementation as soon as possible. CMS appears to be proposing a possible implementation date of Jan. 1, 2018, one year after the mandated implementation date. The agency states that the delay is necessary due to the timing of the rulemaking cycles. CMS proposes that the first applications for clinical decision support mechanisms (CDSMs) be accepted from the date of publication of the CY 2017 final rule until Jan.1, 2017, with the announcement of the qualified CDSMs to be made by June 30, 2017.
Additionally, CMS proposed a set of eight priority clinical areas and indicates that providers may have a choice of using a CDSM that includes a comprehensive set of AUC or one that focuses on the eight priority clinical areas. The ACR will provide extensive comments on these proposals to CMS.
CMS estimates a CY 2017 conversion factor of $35.7551, which reflects the 0.5 percent update specified by the Medicare Access and CHIP Reauthorization Act, a budget neutrality adjustment of -0.51 percent, and an adjustment due to the non-budget neutral 5 percent MPPR for the professional component of imaging services. Overall, this is a slight decrease from the current conversion factor of $35.8043. The budget neutrality decrease is largely a result of proposals to begin compensating primary care physicians for “prolonged services and complex care management services, cognitive impairment assessment and care plan services, psychiatric collaborative care management and services provided to patients with mobility impairments."
CMS estimates an overall impact of the MPFS proposed changes to radiology to be a 1 percent decrease, while interventional radiology would see an aggregate decrease of 7 percent and radiation oncology and nuclear medicine a 0 percent change if the provisions within the proposed rule are finalized. The reimbursement decrease for interventional radiology is a result of CPT code restructuring and revaluation of some high volume codes in the “misvalued codes” initiative. ACR staff are preparing a detailed code level analysis of the impacts of the proposed rule and will make this available to members in the coming weeks.
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