November 15, 2018

ACR Sees Positive Trends in CY 2019 MPFS Final Rule

The American College of Radiology (ACR) has found in its detailed analysis of the Calendar Year (CY) 2019 Medicare Physician Fee Schedule (MPFS) Final Rule that most medical imaging practitioners will see few changes in their overall reimbursements next year.

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

The proposed reductions for radiation oncology and radiation therapy centers were somewhat mitigated by changes to the proposed updates to the practice expense inputs for radiation oncology equipment. CMS initiated a market research contract with StrategyGen to conduct an 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 1300 supplies and 750 equipment items currently used as direct PE inputs. The ACR was also pleased that CMS chose to maintain the 2018 values for ultrasound equipment for 2019.

In the final rule, CMS made several refinements to proposed valuation of new and revised codes, based on feedback from stakeholders. While CMS maintained its proposed valuation for over 50 percent of the radiology-pertinent codes, the agency did increase the valuation for the four breast MR codes as well as the contrast-enhanced ultrasound base code. Additionally, CMS is maintaining the current 2018 values for the 20 X-ray codes that were valued by the American Medical Association Relative Value Scale Update Committee (RUC) via a crosswalk methodology in lieu of the standard RUC survey. All of these codes were specifically addressed by the ACR and American Society of Neuroradiology (ASNR) when we met with CMS on Oct. 17 at the Baltimore headquarters.

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 Jan. 1, 2020. CMS will use of a series of G-codes and modifiers for claims processing.

The ACR will submit comments on the CY 2019 MPFS final rule by the Dec. 31 due date. For questions about the rule, please contact Katie Keysor at