As the American College of Radiology (ACR) continues to conduct a detailed analysis of the Medicare Physician Fee Schedule (MPFS) final rule for 2017, it has become clear that many radiology procedures that are subject to the Deficit Reduction Act of 2005 (DRA) payment cap will face significant reimbursement cuts in 2017. The DRA caps technical component payment for advanced imaging services at the lesser of the MPFS or the Hospital Outpatient Prospective Payment System (HOPPS) payment rate.
Many magnetic resonance imaging (MRI) codes are among the hardest hit procedures, with average reductions from 4 to 19 percent, though some are as high as 58 percent. For example, CPT® code 73718 (Magnetic resonance (eg, proton) imaging, lower extremity other than joint; without contrast material(s)) faces a reduction of 17.1 percent and CPT code 74712 (Magnetic resonance (eg, proton) imaging, fetal, including placental and maternal pelvic imaging when performed; single or first gestation) faces a 58.7 percent reduction in TC reimbursement.
In 2016, the Centers for Medicare & Medicaid Services (CMS) implemented a provision within the Protecting Access to Medicare Act of 2014 (PAMA) to phase in payment reductions over a two-year period if the total relative value units (RVUs) for a service for a year would be decreased by 20 percent or more.
In our comment letter for the 2017 Medicare Physician Fee schedule proposed rule, the ACR asked CMS to apply the same phase-in policy to DRA reductions, as this would capture the spirit of the legislation. In the final rule, CMS responded that since PAMA mandates that the phase-in policy apply to RVU reductions, they do not have the authority to apply it to DRA reductions.
The ACR is preparing CPT code-specific impact tables which will be posted to the website by the first week in December. These tables will allow members to assess the impact of the Medicare Physician Fee Schedule on their individual practices.