March 6, 2024

The American College of Radiology® (ACR®) met with the Medicare Payment Advisory Commission (MedPAC), Feb. 27, to discuss imaging-related artificial intelligence (AI) software. The College provided MedPAC with background information about the current AI landscape and provider experiences with tools on the market. MedPAC is a non-partisan, independent legislative branch commission created to advise Congress about Medicare-related issues.

Greg Nicola, MD, FACR, Chair of the ACR Commission on Economics, and College staff discussed factors that should be considered from a regulatory standpoint to ensure patient safety and efficacy of the AI software. “We are pleased by the positive reception from MedPAC during our discussion in which we highlighted opportunities and precautions for reimbursement for this promising technology,” Dr. Nicola said.

At the meeting, ACR mentioned the importance of maintenance of AI software to combat data drift, with the potential for future formation of practice parameters and accreditation. As the AI market evolves, thoughtful assessment will be required when addressing where AI software belongs in the payment schedule. The Centers for Medicare and Medicaid Services established separate payment for Software as a Service (SaaS) codes under the Hospital Outpatient Prospective Payment System (HOPPS).

MedPAC previously discussed aspects of Medicare’s payment policies for AI software at its November public meeting. Commissioners stressed the significance of incentivizing the development of software that leads to substantial and measurable improvement in clinical outcomes with appropriate reimbursement while remaining affordable for beneficiaries and taxpayers. Concerns about separate versus bundled payments for SaaS were also shared, as MedPAC has long supported larger bundled payments. This is a newer topic of discussion for MedPAC, so additional dialogue is expected.

For questions, contact Kimberly Greck, ACR Senior Economic Policy Analyst.


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