September 16, 2020

Advocating for the Suspension of Budget Neutrality Requirements

Alex Podlaski, MD, MS, is a radiology resident at Case Western/MetroHealth and the ACR-RFS AMA Delegate and Advocacy Liaison
Person on phone with many thumbs up emojis floating above it

On Aug. 3, CMS released the proposed Medicare Physician Fee Schedule (MPFS) for 2021. This fee schedule makes changes to payment provisions regarding the Quality Payment Program (QPP). The ACR has already expressed public disappointment regarding the decision to move forward with the new coding structure for the office/outpatient evaluation and management (E/M) codes. CMS budget neutrality requirements dictate that boosting reimbursements for E/M coding for providers will in turn decrease reimbursements for specialties and providers who do not bill for E/M codes regularly.

To understand the economic impact this will have on the fields of diagnostic radiology, IR, nuclear medicine and radiation oncology, we must examine how E/M codes work. E/M services require the documentation of three key components: history, examination, and medical decision-making. For specialties like radiology and radiation oncology, E/M coding comprises a very small portion of billed services. Performing and interpreting imaging studies is an example of a service which does not meet the requirements for E/M coding. Thus, when reimbursements are tied to E/M services, there are negative fiscal implications for providers and specialties such as diagnostic radiology, IR, and radiation oncology. Current estimates show that the proposed MPFS will decrease Medicare reimbursements to diagnostic radiology by 11%, to IR by 9%, nuclear medicine by 8%, and to radiation oncology by 6%. This translates to over 5 billion dollars in the next decade in lost reimbursement. This is predicted to result in dramatic reductions in patient access, especially in underserved areas among the ongoing COVID-19 pandemic.

The ACR is urging Congress to wave the budget neutrality requirement and avert the impending patient access limitations. The MPFS is scheduled for implementation on Jan. 1, 2021. As trainees, the most impactful thing we can do is contact our Congressional representatives and urge them to waive the budget neutrality requirement.

Here are the best ways to do this:

  • Identify your Congressperson. Information on finding your representative can be found at:
  • Once you know who your Congressperson is, let them hear your opinion! Tweeting at them is a great way to raise public awareness, but just remember to do it professionally. Alternatively, sending them an email is a time-tested and effective means of communicating your reasons for opposing budget neutrality.
  • The Radiology Advocacy Network has put together a letter-writing resource that makes it easier than ever to message your members of Congress. This resource shows you who your Representatives and Senators are and provides an editable template email to send them. This resource can be found here:

Here are some example tweets that you can send:

  • As a [radiologist/radiation oncologist] in [insert location], I am deeply disturbed by @CMSGov‘s plan to move forward with an 11% cut to Medicare reimbursement rates. This is not in the best interest of patients, providers, or public health. Join me in asking Congress to #StopTheCuts!
  • Big cuts by @CMSGov to radiology reimbursements will threaten practices and harm patient access to the screenings and imagery that keep them healthy and help them recover. Tell Congress: #StopTheCuts – #Radvocacy

Most importantly, be sure to stay active as a #Radvocate shaping the future of the profession!