Nick Bartz, Imaging Performance Partnership
Last week, CMS published their 2013 proposed rules for the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS). The Imaging Performance Partnership has made our initial analysis of the two rules and pulled out the most meaningful implications for your program. Please keep in mind that any part of these proposed rules could change when CMS releases the 2013 final rules at the end of this year.
Continuing to expand the MPPR
Last year, in their 2012 Physician Fee Schedule Final Rule, CMS established a 25% reduction to the professional component of advanced imaging services for the second and subsequent exam when furnished to the same patient, in the same session, and when read by practitioners in the same practice. Amid significant lobbying efforts by the ACR, among others, CMS changed course and announced that due to “operational limitations,” payment would only decrease if the same physician interpreted multiple exams from a single patient in a single setting.
In the proposed rule for 2013, CMS stated that they have dealt with any “operational limitations” and propose again to apply the MPPR when multiple services are furnished to a patient in the same session by multiple physicians in the same practice.
Perhaps more significantly, CMS also proposed to expand the MPPR to the technical component of diagnostic procedures performed in cardiology and ophthalmology, including many procedures performed by interventional radiologists. CMS has again cited internal studies that reveal significant efficiencies when these procedures are furnished together, and consequently propose to implement a 25% reduction to the technical component of second and subsequent diagnostic cardiovascular and ophthalmology imaging services.
As with other implementations of the MPPR, the reduction would apply to second and subsequent exams performed on the same patient, in the same session, either by a single practitioner, or multiple practitioners in the same practice. The full list of cardiovascular and ophthalmology services now subject to the MPPR can be found in tables twelve and thirteen of the proposed rule.
Allowing nonphysician practitioners to order portable X-rays
Recognizing that nonphysician practitioners are becoming an increasingly important component of clinical care, CMS has proposed to allow nonphysician practitioners acting within the scope of their Medicare benefit and state law to order portable X-ray services. This would revise their existing regulations, which limit ordering of portable X-ray services to only a MD or DO.
Provided that all practitioners act within their state’s scope of practice and the scope of their Medicare benefit, the proposal would expand the list of practitioners able to order portable X-rays to:
- Nurse practitioners
- Clinical nurse specialists
- Physician assistants
- Certified nurse-midwifes
- Doctors of optometry
- Doctors of dental surgery
- Doctors of dental medicine
- Doctors of podiatric medicine
- Clinical psychologists
- Clinical social workers
Cumulative impact of proposed changes on physician revenue by specialty
In the MPFS proposed rule, CMS estimated revenue reductions for each specialty, stemming from proposed changes to the physician fee schedule in 2013. The graph below outlines potential revenue reductions for imaging-heavy specialties. Please note that the “Radiology” category refers largely to radiologist’s professional revenue, while “Diagnostic Testing Facilities” refers to the technical revenue received by physicians who provide imaging services in independent diagnostic testing facilities.
New cuts to hospital reimbursement for combined abdomen/pelvis CT scans
On the hospital outpatient side, CMS resolved to continue assigning the AMA’s new bundled abdomen/pelvis CPT codes to their own specific ambulatory payment classifications (APCs 0331 and 0334). This will come as welcome news given CMS’s alternative: assign the bundled codes to the much lower reimbursed APCs for single CT scans (0332, 0333). However CMS has substantially revised their cost estimates for the new abdomen/pelvis CT APCs and, consequently, reimbursement for the new APCs will significantly decline in 2013. The tables below outline changes to reimbursement for the combined abdomen and pelvis CT APCs, as well as other APC codes seeing steep reimbursement reductions.
Some welcome news for hospitals in vascular imaging
In more welcome news, CMS has substantially increased reimbursement for vascular imaging, after slashing it by 27% in 2012. The following table outlines the five codes seeing the highest potential reimbursement increases in 2013.
As we continue to examine the rule, make sure to look out for our Imaging Payment Update for 2013 in the coming weeks.
For more information on hot topics in imaging, register for the 2012 Imaging Performance Partnership national meeting.