September 16, 2021

ACR Submits Comments on the 2022 MPFS Proposed Rule

The American College of Radiology® (ACR®) submitted comments to the Centers for Medicare and Medicaid Services (CMS) Sept. 13, that addresses numerous issues and make specific recommendations related to the 2022 Medicare Physician Fee Schedule (MPFS) Proposed Rule.

CMS in the proposed rule released July 13 proposed to update the wages for clinical labor staff, which have not been updated since 2002. Clinical labor staff, medical supplies and equipment costs are components of direct practice expense. The ACR commented that we are deeply concerned about the devasting redistributive effect this update would impose on radiology, especially interventional radiology and radiation oncology services, as well as other medical specialties where the practice expense costs rely primarily on supply or equipment items. The ACR asked CMS to not move forward with their proposal for 2022 and allow time for the agency and stakeholders to further evaluate how the Bureau of Labor Statistics data — the main source used to update wages —is used and applied. If CMS finalizes the wage changes with other changes, the reductions will be an estimated 2% for radiology, 9% for interventional radiology, 2% for nuclear medicine, 5% for radiation oncology and 11% for radiation therapy centers.

The Consolidated Appropriations Act, 2021 included a 3.75% adjustment to the 2021 conversion factor that reduced payment cuts to radiologists from 10% to 4%. If Congress does not intervene and there is no 3.75% bump to the proposed 2022 conversion factor, the potential higher end of the overall percent reduction for 2022 is approximately 6% for radiology, 13% for interventional radiology, 5% for nuclear medicine, 8% for radiation oncology and 14% for radiation therapy centers.

The ACR also commented in support of CMS proposed changes to Appropriate Use Criteria for advanced diagnostic imaging related to claims processing.

In addition to these topics, the ACR commented about codes involving innovative technology, valuation of specific codes, the proposal to remove selected national coverage determinations and the Quality Payment Program.

CMS will take into consideration comments received from all stakeholders to the proposed rule and will release its final rule in November.

For questions about the 2022 MPFS proposed rule and ACR comments, please contact Angela Kim, Senior Director for ACR Economics and Health Policy.