The American College of Radiology® (ACR®) has prepared impact tables that expose how the 2022 Medicare Physician Fee Schedule (MPFS) proposed rule affect specific radiology related tests and procedures. The rule would negatively affect medical imaging payment rates if accepted without modification by the Centers for Medicare and Medicaid Services (CMS), particularly for diagnostic and interventional radiology, nuclear medicine, and radiation oncology. The ACR is working with other provider organizations to urge congressional leadership to retain the 3.75% increase to the conversion factor (CF) contained in the 2021 MPFS through FY 2023.
The tables cover specific changes in reimbursement rates and relative value units (RVUs) between calendar years 2021 and 2022 for each Current Procedural Terminology® (CPT) code. The ACR analysis includes spreadsheets for the 70,000 series CPT codes and the non-70,000 CPT codes billed by radiologists, interventional radiologists and/or radiation oncologists.
CMS estimates an overall impact of the MPFS proposed RVU changes to radiology to be a 2% decrease, while interventional radiology would see an aggregate decrease of 9%, nuclear medicine a 2% decrease, and radiation oncology and radiation therapy centers a 5% decrease. The estimated decreases are due to changes in RVUs, redistributive effects of the CMS proposed clinical labor pricing update and phase-in implementation of the previously finalized updates to supply and equipment pricing.
The tables show that the reimbursement rate changes are larger than the proposed RVU changes due to the expiration of the 3.75% adjustment to the 2021 conversion factor mandated by the Consolidated Appropriations Act, 2021 (P.L.116-260). If Congress does not intervene and there is no 3.75 percent bump to the proposed 2022 conversion factor, the potential higher end of the overall percent reduction for 2022 is approximately 6% for radiology, 13% for interventional radiology, 5% for nuclear medicine, 14% for radiation therapy and 8% for radiation oncology.
Questions about the MPFS proposed rule impacts should be directed to Katie Keysor, ACR Senior Director of Economic Policy.