Sept. 14, 2023

The American College of Radiology® (ACR®) submitted comments to the Centers for Medicare and Medicaid Services (CMS) related to the 2024 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule that address radiology-specific issues and make specific recommendations.

CMS requested feedback on potential changes to the current packaging policy for diagnostic radiopharmaceuticals. The College recommended that CMS establish separate payment for diagnostic radiopharmaceuticals, including a per day cost threshold based on average sales price (ASP) + 6% methodology. The ACR also signed on to a coalition letter urging CMS to pay separately for these drugs, citing diminished patient access to these diagnostic tools that are vital to delivering the most appropriate treatment course.

The ACR also submitted comments related to other proposals in the rule, including the potential adoption of a new radiology-specific Hospital Outpatient Quality Reporting (OQR) Program measure, recommending that CMS take a considered approach to implementation, as well as renaming the measure.

CMS will take all comments from stakeholders into consideration and release its final rule in November. If you have questions about ACR’s HOPPS proposed rule comments, contact Kimberly Greck, ACR Senior Economic Policy Analyst.


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