Raymond W. Liu, MD, Chair of the American College of Radiology® (ACR®) Commission on Economics Interventional & Cardiology Committee, contributed this post.

As part of the 2022 Medicare Physician Fee Schedule (MPFS), the Centers for Medicare and Medicaid Services (CMS) proposes increased wages for clinical labor staff. Clinical labor staff, medical supplies and equipment costs are components of the direct practice expense inputs (DPEI); in other words, costs directly associated with the provision of a service or procedure. The three components are budget neutral, which means that an increase in payment for one component typically means a proportional decrease in payment in the other components.

As a result of applying budget neutrality, radiology specialties like interventional radiology (IR) and radiation oncology (RO) — which have high medical supply and equipment costs and lower clinical labor costs — are slated for potentially significant reimbursement reductions, estimated at -9% for interventional radiology and -5% for radiation oncology. Diagnostic radiology and nuclear medicine have an estimated -2% impact. These impacts will be greater if Congress does not extend the 3.75% increase to the conversion factor. While we support more equitable pay for our clinical labor staff, it should not come at the cost of access to high quality care for our radiology patients.

We must take action to protect radiology practices and access to quality care for our patients. That is why the ACR, in conjunction with the Society of Interventional Radiology and other impacted physician organizations, is exploring all regulatory and legislative options to mitigate these reimbursement cuts. The ACR is finalizing a call to action for members to send to CMS in combination with an ACR comment letter on the 2022 MPFS Proposed Rule. This issue is a top priority of our advocacy efforts this fall, just as the ACR and our members fought against—and ultimately secured significant reduction of—payment cuts due to evaluation and management coding changes at the end of 2020.

Together, we will preserve equitable access to care and safeguard our specialty in the communities we serve.

Stay tuned for the latest updates on our advocacy efforts.

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