Government Relations
GR News
November 6, 2009
Update on CMS Final Payment Rules
On Friday, October 30, the Centers for Medicare and Medicaid Services (CMS) issued two final rules, one for physician payment (Medicare Physician Fee Schedule [MPFS]) and the other for hospital outpatient procedures (Hospital Outpatient Prospective Payment System [HOPPS]).
There are major reductions ahead for reimbursement of imaging procedures, especially if Congress does not lift implementation of the Sustainable Growth Rate (SGR) rule which would cause an across-the-board 21.5% decrease in payment for physician services beginning in January 2010. (For more information on the SGR, please click here.)
Two issues affect reimbursement for nuclear medicine in particular. First, in 2010 CMS will start a four-year transition to implement the results of the AMA Physician Practice Information Survey (PPIS). SNM believes the survey data were not representative of the actual practice expenses for nuclear medicine, and their use could have a profound negative impact on the calculation of nuclear medicine and other imaging practice expenses. SNM is working to formulate a response to CMS.
Second, CMS made a major reduction in payment for myocardial perfusion imaging (MPI). The MPI codes were identified by CMS and the AMA Five Year Review Identification Workgroup as codes that were performed so often with the add-on codes for wall motion and ejection fraction that they should be bundled (for more information on these codes, please click here). New MPI CPT codes were approved for 2010 that bundle MPI plus wall motion and ejection fraction into single codes. In its recommendation to CMS, the AMA RVS Update Committee (RUC) reduced the total work attributed to the new bundled codes--and then CMS reduced it even more. SNM is surprised and concerned that CMS did not accept the AMA RUC recommendations.
Compounding the negative impact, CMS has treated these new bundled MPI codes as "new or significantly revised" CPT codes. This means that they forgo the PPIS four-year transition period; that is, the full reduction is applied for 2010. SNM believes that CMS should issue a technical correction regarding this phase-in which would provide some minimal relief from the major reduction in payment in 2010 for the four new MPI codes. SNM will work with CMS and other specialty societies to try to correct this before January 1.
Initial review of the HOPPS rule indicates that reimbursement to the hospitals is fairly stable, with mostly modest increases or decreases. Although there is a substantial decrease for the tumor SPECT code--CPT 78803 Radiopharmaceutical localization of tumor or distribution of radiopharmaceutical agent(s); tomographic (SPECT)--there is a substantial increase for cardiac PET. SNM has prepared a code by code comparison showing 2009 and the final 2010 HOPPS rates, which is available here.
We are still in the process of analyzing the full impact of the rules, and we will send additional announcements as we conclude our analysis and determine our next steps. As always, please continue to check the SNM Coding Corner for more information.