ACR Bulletin

Covering topics relevant to the practice of radiology

A No-Win Situation

We can escape the problems of the current health system by rapidly rewriting our story and reinventing how we provide care.
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The Commission’s priority is fostering and supporting innovation inside our profession. The creation of new value is the key to our success, and likely the only long-term strategy for the mitigation of reimbursement decline.

February 22, 2022

Annually, the ACR Commission on Economics sets forth goals and strategic initiatives that are important to the economic interests of ACR members. Part of this process involves sharing a framework with the broader membership for transparency and feedback. It is an honor to represent our vast constituency on these vital issues, which ultimately enable all of us to provide high-quality, equitable patient care.

The first set of goals and initiatives are seemingly consumed every year by maintaining adequate reimbursement within the static budget-neutral Medicare Physician Fee Schedule. This challenge has evolved rapidly. Over the last decade, our focus was centered on maintaining the value of imaging services in front of the AMA Relative Value Scale Update Committee — the Committee with deep influence on how Medicare ultimately values our services. Most of our core patient services have now been valued, but the reimbursement cuts have escalated as the fixed allocation of money inside the fee schedule is now being distributed to services radiologists don’t typically provide.

The only course of action for our organization is to partner with myriad other specialties also facing the same challenges. As a group, we can more strongly advocate that Congress add new funds to negate the reimbursement cuts in the budget-neutral environment. This task is predominantly handled by the ACR Government Relations (GR) team, with support from the Commission. Our team of volunteers will continue to bring firsthand information to our GR team about additional pending revaluations occurring inside the fee schedule so that action and coalition-building happens without delay. Foreseeable challenges include revaluations of multiple additional evaluation and management code families, expansion of telehealth and telecommunication services, and rapidly growing AI applications — each vying for dollars in the fee schedule.

The Commission’s priority is fostering and supporting innovation inside our profession. The creation of new value is the key to our success, and likely the only long-term strategy for the mitigation of reimbursement decline. Our teams constantly interact with researchers, practice leaders, and the broader imaging industry. We will continue to look at new ways in which radiologists can add value to the healthcare continuum by concentrating resources on payment for value-based care-coordination activities, payments for already existing activities not adequately reimbursed under the current fee schedules, and innovation around payments for promoting health equity. Our CPT® team is working diligently on these opportunities and is always open to member feedback.

The Commission will maintain active vigilance and a firm stance against aggressive tactics by commercial payers who only measure radiologist’s value by cost. Steerage based on cost alone is harmful to our healthcare system, forcing practices to the lowest common denominator. These tactics disincentivize groups from maintaining robust quality assurance processes that are vital to high-quality patient care, replacing them instead with factory-like relative value unit measures. They also discourage the upgrade of equipment and hamper innovation that is vital to advancing healthcare into the future. Much of imaging has been labeled as “low value” by payers and policymakers — yet we know our clinical colleagues value radiology and radiologists. As proof, one only has to consider their relentless requesting of our services and demand for immediate image interpretation. This disconnect between policy and reality is counterproductive, and our Commission will continue to educate all payers about these harmful policies.

This advocacy is now even more imperative considering the No Surprises Act and subsequent regulatory language written by the U.S. Department of Health and Human Services (read more at Inordinate leverage has been granted to commercial payers to unilaterally act in their own best interests. We have already seen the consequences of these rules through documented threatening letters to in-network, high-quality radiology groups in the state of North Carolina to reduce costs immediately or have their contracts cancelled. Not one of these letters mentions quality, access, or value of care.1

A host of other issues are on our radar for the coming year. However, it is clear that the current healthcare system is a no-win situation for radiology. Much of the value we provide is either unrecognized or unpaid, leading to less-than-optimal outcomes. The old adage of when there is a care gap, it is often because of a payment gap rings true throughout our profession — as it has for years for our primary care colleagues. The Commission is dedicated to the process of reinvention using all the resources we have at our disposal — including the expertise of our staff and volunteers, work groups, consultants, coalitions outside our specialty, members, and our patients.


1. Blue Cross Blue Shield of North Carolina letter to network providers; November 5, 2021.

Author Gregory N. Nicola, MD, FACR,  Chair of the Commission on Economics