In formal comments, the American College of Radiology (ACR) has expressed satisfaction with provisions in the calendar year (CY) 2019 Hospital Outpatient Prospective Payment (HOPPS) proposed rule that would delay implementation of its disputed CT and MRI cost center policy until 2020, but continues to encourage CMS to terminate the policy.
The delay reflects recommendations from ACR representatives at a February 12, 2018, meeting with CMS. It was at that meeting that the ACR challenged the accuracy of cost calculations that influenced the cost center policy’s development.
In its September 24, 2018, comment letter, the ACR again asked CMS to terminate the regulatory requirement for hospitals to use the CT and MRI cost centers and instead set weights based on a single diagnostic radiology cost-to-charge ratio (CCR). This is the same policy that CMS applied before it created separate CT and MRI standard cost centers in 2011.
The ACR’s comments also addressed other relevant proposals in the CY 2019 HOPPS proposed rule:
- Proposed calculation and use of CCRs
- Low-dose CT lung cancer screening
- Radiology and imaging procedures and services; imaging Ambulatory Payment Classifications (APCs)
- Payment rates under the Physician Fee Schedule (PFS) and adjusted HOPPS for items and services furnished by excepted off-campus provider-based departments of a hospital
- Proposed APC placement of new and revised CY 2019 Category I and III CPT codes
- Endovascular revascularization procedures
- Movement of brachytherapy and stereotactic radiosurgery (SRS) procedures from comprehensive-APCs (C-APCs) to regular APCs
- Moving C11 choline off the pass-through payment list
In the HOPPS proposed rule, CMS requested stakeholder comments on whether the agency should maintain the current imaging APC structure and on the proposed Healthcare Common Procedure Coding System (HCPCS) code reassignments within imaging APCs.
The ACR encouraged CMS to improve stability across and within APCs, and it will continue to work with CMS to examine how to responsibly add more imaging APC levels and improve stability to the imaging with and without contrast APCs.
Please direct your questions about the CY 2019 HOPPS proposed rule or comment letter to Pam Kassing at firstname.lastname@example.org or Christina Berry at email@example.com in the ACR economics department.