Professional Component Multiple Procedure Payment Reduction

Oppose Further Application of a Multiple Procedure Payment Reduction to the Professional Component of Diagnostic Imaging Services

Thanks to the tireless efforts of the ACR’s physician leadership and membership working in concert with the Government Relations Department, H.R. 2029, the Consolidated Appropriations Act of 2016 included provisions to substantially roll back the 25% professional component (PC) multiple procedure payment reduction (MPPR).

Effective January 1, 2017, the PC MPPR will be lowered from 25% to 5% and this new, reduced percentage would apply to one or more radiologists who interpret multiple images from the same patient, during a single session, on the same day. The inclusion of provisions substantially reducing the PC MPPR marks the culmination of more than four years of sustained federal advocacy efforts surrounding this flawed reimbursement cut and the ACR applauds the leaders of the House and Senate for their leadership on this important issue.

Issue


Application of an MPPR to the professional component of diagnostic imaging services performed on the same patient on the same day is an arbitrary and imprecise tool to control Medicare spending. This particular policy recommendation overestimates perceived efficiencies within the professional component, is not supported by sound data, nor was it developed with substantial physician input.

Since each imaging study produces its own set of images requiring individual interpretation, the radiologist is ethically and professionally obligated to expend the same amount of time and effort interpreting each image, regardless of the date of service. A peer-reviewed, expert study shows that professional component efficiencies vary across modalities and range from a minimum of 2.96 percent for CT to a maximum of 5.45 percent for ultrasound.

Because reductions to the professional component primarily impact radiologists who, as referral-based physicians, rarely order the imaging studies they are asked to interpret, CMS’ attempts to impose an MPPR to the professional component of select advanced diagnostic imagines services also fails to adequately address inappropriate utilization. Imposition of this policy will also make it difficult for radiologists to keep free-standing imaging facilities open for business, thus threatening patient access to important diagnostic imaging services.

Issue Background


In response to incorrect perceptions by some policymakers surrounding overutilization of diagnostic imaging services, the practice of radiology has endured substantial reimbursement cuts implemented both through the legislative and regulatory process. In recent years, the Medicare Payment Advisory Commission (MedPAC) and the Centers for Medicare and Medicaid Services (CMS) sought to control imaging growth through reimbursement cuts that impose a Multiple Procedure Payment Reduction (MPPR) to multiple diagnostic imaging services administered by the same physician, to the same patient, during a single office visit.

MedPAC and CMS traditionally applied MPPR policies to the technical component of advanced diagnostic imaging services, or the cost of equipment, non-physician personnel, and medical supplies. In theory, MPPR policies are designed to lower Medicare costs and improve program efficiency by modifying multiple payments for duplicative or overlapping services performed consecutively on the same day. Yet, MedPAC took the unprecedented step of recommending the application of an MPPR policy to the professional component of diagnostic imaging services in its June 2011 Annual Report.

In July 2011, CMS, after consulting MedPAC’s recommendation, included provisions in the 2012 Medicare Physician Fee Schedule Proposed Rule to impose a 50 percent MPPR to the professional component of select advanced diagnostic imaging services (i.e. CT, MRI, and Ultrasound). Although slightly different from MedPAC’s initial recommendation, CMS’ proposed policy would result in an inappropriate and unsubstantiated reimbursement cut for radiologists. The value of physician-radiologist interpretations of examinations that usually contain hundreds of images, as well as providing the results of these analyses into the final written medical report for the referring physicians, will be severely undermined.

Despite tremendous opposition from the ACR, CMS ultimately included a 25% MPPR to the professional component of advanced diagnostic imaging services in its final physician fee schedule rule which took effect on January 1, 2012. Furthermore, CMS expanded this already questionable policy through the 2013 Medicare Physician Fee Schedule Final Rule which took effect on January 1, 2013. Now, the 25 percent PC MPPR applies equally to both individual and multiple radiologists interpreting multiple imaging studies from the same patient, on the same day, irrespective of practice setting. ACR believes this latest expansion of the policy, once again, reflects CMS’ lack of understanding of how medical imaging is practiced.

Recommendations


  • Urge your Senators and Representatives to cosponsor H.R. 2043/S. 1020, the Diagnostic Imaging Services Access Protection Act, legislation which seeks to repeal the current PC MPPR as well as require CMS to utilize comprehensive, empirical data when working to impose similar reimbursement cuts in the future. Versions of the Diagnostic Imaging Services Access Protection Act which were introduced in the 112th and 113th Congresses generated tremendous bipartisan support.
  • Future attempts to apply an MPPR to the professional component of select advanced diagnostic imaging services must recognize that comprehensive data indicates that professional component efficiencies vary across modalities and range from a minimum of 2.96 percent for CT to a maximum of 5.45 percent for Ultrasound.