The American College of Radiology® (ACR®) submitted comments to the Centers for Medicare and Medicaid Services (CMS) related to the 2023 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule that address radiology-specific issues and make specific recommendations.
CMS proposes establishment of Healthcare Common Procedure Coding System (HCPCS) C-codes to pay for Software as a Service (SaaS) procedures, a new reimbursement approach to approved New Technology services. The ACR provided feedback about how to appropriately identify and reimburse SaaS procedures, cautioning against relying on C-Codes as a long-term solution. The College also addressed placement and reimbursement of new and existing common procedural terminology codes for imaging services in its comments.
Other proposals the ACR commented on are about payment policies for therapeutic radiopharmaceuticals, prior authorizations of facet joint interventions and requirements for the hospital outpatient quality reporting program.
CMS will take all comments from stakeholders into consideration and release its final rule in November. If you have questions about the ACR HOPPS proposed rule comments, contact Kimberly Greck, ACR Economic Policy Analyst.