September 09, 2021

Impact of MPFS Proposed Rule on Radiology

The U.S. Centers for Medicare & Medicaid Services (CMS) recently released the proposed rule for the Medicare Physician Fee Schedule (MPFS) for calendar year 2022. In July, the ACR released a preliminary summary of radiology provisions in the rule, including:

  • Reimbursement cuts for radiology. The ACR prepared impact tables that expose how the MPFS proposed rule could affect specific radiology-related tests and procedures. The rule would negatively affect medical imaging payment rates if accepted without modification by CMS, particularly for diagnostic and interventional radiology, nuclear medicine and radiation oncology. Learn more »

  • Appropriate Use Criteria updates. The MPFS rule would move forward with the appropriate use criteria program for advanced diagnostic imaging services mandated by the Protecting Access to Medicare Act of 2014 with the penalty phase scheduled to begin on Jan. 1, 2023 (or the first of the year following the end of the COVID-19 public health emergency). Learn more »

Read the ACR radiology-specific summary to learn more about critical provisions that might impact radiology or radiation oncology.

The ACR Responds to Proposed Quality Program Changes

Based on the analysis of the MPFS proposed rule, the ACR drafted a comment letter to CMS that highlights potential impacts on radiology participation in the Quality Payment Program, including the challenges regarding cost measures and the transition to digital quality measures. The ACR will also present arguments against proposed CMS changes, including:

  • Removal of two radiology MIPS quality measures:
    • 195: Stenosis Measurement in Carotid Imaging Reports.
    • 225: Reminder System for Screening Mammograms.
  • Restriction of quality bonus points.
  • Requiring 80% data completeness, especially for rural radiology practices.

The ACR also requested clarification on subgroup reporting and offered support for the proposed 5-point floor for new MIPS measures.

Watch this newsletter or the ACR Media Center for more details about the ACR response to the MPFS proposed rule.