September 15, 2017

ACR Seeks Adjustments to 2018 HOPPS Proposed Rule

In detailed comments submitted Sept. 11, the American College of Radiology (ACR) expressed a mixture of appreciation and disappointment with various aspects of Medicare’s Calendar Year 2018 Hospital Outpatient Payment System (HOPPS) proposed rule.

The ACR was partially satisfied with plans for HOPPS’ CT MR cost center methodology. It expressed appreciation for the Centers for Medicare & Medicaid’s (CMS’) decision to delay the methodology’s implementation. But the College stressed that it would prefer to discontinue the use of these separate cost centers. An ACR analysis shows their use decreases the accuracy of payments for hospital outpatient CT and MRI while having a detrimental effect on the accuracy of radiology reimbursement in other payment systems as well.

The ACR expressed appreciation for the addition of a fifth level to the Without Contrast Imaging Ambulatory Payment Classification (APC) family. The ACR presented CMS with code-level recommendations for APC placements to stabilize payments for diagnostic radiology codes. Additionally, the ACR asked CMS to create a fourth level for the With Contrast Imaging APC family to add further stability, especially for the higher cost radiology studies.

The ACR expressed disappointment with CMS’ proposal to continue the placement of low-dose CT for lung cancer screening (LDCT) in the lowest level imaging APC. The College reiterated its belief that CMS should place LDCT in APC 5522 (Level 2 Imaging Without Contrast) due to its clinical similarity with 71250 (non-contrast chest CT) until such time as the claims data has matured, meaning enough cost data has been compiled to use it to set rates.

The ACR will continue to work with CMS to remedy these issues. For more information, contact the ACR’s Dominick Parris at