The American College of Radiology® (ACR®) commented on numerous issues and made specific recommendations in an Oct. 2 letter to the Centers for Medicare and Medicaid Services (CMS) concerning the 2021 Medicare Physician Fee Schedule (MPFS) proposed rule and proposed changes to the Quality Payment Program.
The ACR commented on the proposed 10.61% budget neutrality adjustment to the conversion factor, largely a result of changes to the Evaluation and Management (E/M) services. The ACR expressed concern about the sizable cuts this update will impose upon radiology and other medical specialties who do not frequently bill E/M codes, particularly in light of the COVID-19 public health emergency. The ACR asked CMS to delay any changes to the E/M coding and valuation that will result in significant payment reductions to providers who are already financially strained by COVID-19. In addition, the ACR opposed the implementation of GPC1X, a code describing the complexity associated with visits that serve as a focal point for all medical care or for ongoing care related to a patient’s single, serious or complex chronic condition. Finally, the ACR opposed the proposed revaluation of the group of code sets that include or rely upon office/outpatient E/M visit valuation and urged CMS to use the resource-based valuation system rather than updating values by rulemaking alone.
If CMS finalizes the changes to the E/M services in CY 2021, the estimated impact according to the proposed rule is 11% reduction to radiology, 9% reduction to interventional radiology, 8% reduction for nuclear medicine, and 6% reduction for radiation oncology and radiation therapy centers.
In addition, the ACR supported the proposed removal of National Coverage Determinations (NCDs) for Magnetic Resonance Spectroscopy and FDG PET for Inflammation and Infection. Removal of the outdated NCDs allows local Medicare Administrative Contractors (MACs) to make coverage decisions for these exams. The ACR also requested that the current NCD for CT colonography for colorectal cancer screening be removed, deferring coverage decisions to the MACs.
The proposed rule also includes a provision to make permanent a policy from the May 1 COVID-19 Interim Final Rule with Comment permitting physician assistants, nurse practitioners and certain other non-physician practitioners to supervise diagnostic tests. The ACR opposed this change in its comments to CMS.
In addition to these topics, the ACR commented on the following topics:
- Outpatient Prospective Payment System Cap List.
- Proposed Valuation of Specific Codes.
- Update on Technical Expert Panel Related to Practice Expense.
- Medicare Shared Savings Program.
- Merit-based Incentive Payment System Value-based Pathways.
- MIPS: Quality Performance Category.
- MIPS: Improvement Activity Performance Category.
- MIPS: Cost Performance Category.
- MIPS: Qualified Clinical Data Registry.
- Alternative Payment Models (APMs): APM Performance Pathway.
- Advanced APMs.
For questions on the 2021 MPFS proposed rule or ACR comments on the rule, please contact Kathryn Keysor.