March 17, 2017

ACR Seeks More Transparency in HOPPS Rulemaking

Representatives of the American College of Radiology (ACR) and its consultant, the Moran Company, met with leaders of two key Medicare payment policy-making groups within the Centers for Medicare and Medicaid Services (CMS) March 9 to discuss recommended changes for the 2018 Hospital Outpatient Prospective Payment System (HOPPS) final rule.

The ACR voiced concerns to top officials with the Hospital and Ambulatory Policy Group (HAPG) and the Division of Outpatient Care (DOC) about their lack of meaningful transparency with regard to the rationale behind the major reorganization of Ambulatory Payment Classifications (APCs) in the CY 2017 HOPPS Final Rule, the apparent abandonment of “clinical similarity” as a driving factor for APC placement and evidence suggesting an unwillingness to address the College’s technical comments during the 2017 rule-making cycle.

On the clinical similarity issue, the ACR presented an alternative APC placement for the CT lung code (G0297) to assign it more appropriate Medicare payment rates and to more closely align it with the placement with CT thorax (71250), which is clinically similar to resource consumption of CT lung. The ACR also argued new codes should be held in specialty-recommended, clinically similar APCs for two to
three years, as is now the case for CMS’ new pass-through drug policy.

The ACR described how an analysis conducted with its consultant revealed the use of CT and MR cost centers produces data that may cause more harm than good. The analysis found at least half of the nation’s hospitals still use a square foot method for calculating overhead for advanced imaging technologies. This means CMS would erroneously cut hospital payments for MRI and CT by an additional 10 percent and 25 percent respectively, if it moves forward with plans to not use any cost data reported under the square foot method next year.

And, the ACR repeated its request for the discontinuation of CMS’s problematic use of the CT and MR cost centers, noting that CT and MR payment rates are more stable when reported with the traditional diagnostic radiology cost center. The College has advocated this approach since 2009.

The ACR will continue to provide CMS with data supporting these positions up to and during the CY 2018 rulemaking cycle. Please contact Pam Kassing at or Dominick Parris with your questions, comments and concerns.