July 26, 2018

ACR Sees Few Big Changes in 2019 MPFS Proposed Rule

The American College of Radiology (ACR) has found in its detailed analysis of the Calendar Year 2019 Medicare Physician Fee Schedule (MPFS) Proposed Rule that most medical imaging practitioners will see few changes in their rates if the rule is implemented as proposed.

The Centers for Medicare and Medicaid Services (CMS) estimates an overall impact of the MPFS proposed changes to radiology and interventional radiology to be a neutral 0 percent change, while nuclear medicine would see an aggregate decrease of 1 percent and radiation oncology and radiation therapy centers a 2 percent decrease if the provisions within the proposed rule are finalized.

The proposed reductions for radiation oncology and radiation therapy centers are primarily a result of changes to practice expense inputs for radiation oncology equipment. CMS initiated a market research contract with StrategyGen to conduct and in-depth and robust market research study to update the MPFS direct practice expense (PE) inputs for supply and equipment pricing for CY 2019. StrategyGen submitted a report with updated pricing recommendations for approximately 1,300 supplies and 750 equipment items currently used as direct PE inputs. The ACR is continuing to review the PE input changes in detail and will provide specific comments to CMS as appropriate.

There are approximately 60 new and revised radiology codes for CY 2019. In the proposed rule, compared to the American Medical Association (AMA) Relative Value Scale Update Committee (RUC) recommendations, CMS proposes to increase values for some radiology codes while decreasing values for others. Our Current Procedural Terminology (CPT®) and Relative Value Scale Update Committee (RUC) teams worked very hard to achieve accurate payment rates for these radiology services. Staff and physician volunteers will prepare detailed comments to address any decreases in values.

Regarding mandatory appropriateness use criteria (AUC) implementation for advanced diagnostic imaging services, the rule reconfirms that ordering professionals must begin to consult specified AUC through qualified decision support mechanisms (CDSMs) on January 1, 2020. CMS proposes the use of a series of G-codes and modifiers for claims processing.

The ACR will submit comments on the CY 2019 MPFS proposed rule by the Sept. 10 due date. For questions about the rule, please contact Katie Keysor at kkeysor@acr.org.