Proposed 2015 Medicare Physician Fee Schedule

The Centers for Medicare & Medicaid Services released the 2015 Medicare Physician Fee Schedule (MPFS) Proposed Rule on July 3. CMS proposes the overall reimbursement impacts for radiology below:

Radiology:  (2%)
Radiation Therapy Centers:  (8%)
Radiation Oncology:  (4%)
Nuclear Medicine:  1%
Interventional Radiology:  (1%)

CMS has proposed in the 2015 MPFS to delete the mammography G-codes, currently the only legitimate way to represent services were performed using tomosynthesis.   CMS has proposed, beginning in 2015, to pay all mammography using established CPT codes. Tomosynthesis would have the same values as a mammogram performed with typical digital or analog technology.

However, CMS has expressed concerns about whether the current values for mammography accurately reflect the professional and technical resource inputs associated with providing tomographic mammography services, since the CPT codes have not recently reviewed for the significant professional time commitments and technological changes that have occurred associated with tomosynthesis. CMS is labeling current mammography CPT codes as potentially misvalued and is requesting that the RUC review these services in terms of appropriate work RVUs, work time assumptions and direct practice expense inputs.

In the interim, CMS proposes to value the CPT codes using the RVUs previously established for the G-codes, which may result in a small reimbursement increase professionally, at least temporarily. CMS believes these values would be most appropriate since they were established to reflect the use of digital technology.

Break Away from the Static

In addition to the tomosythesis codes, CMS proposes adding about 20 radiology CPT codes to their list of potentially misvalued codes. These include select interventional radiology, mammography, MRI of the abdomen, CT of the thorax, chest x-ray, x-ray of the knee, radiation therapy planning and radiation treatment aids codes. Although a case can be made for a reimbursement increase for tomosythesis, the other radiology codes will likely suffer the recent precedent of radiology reimbursement.

Medicare is also reviewing circumstances where it would be appropriate for Medicare to permit payment under the MPFS when radiologists provide subsequent interpretations of existing images.  CMS is trying to determine whether more routine Medicare payment for a second professional component for radiology services reduce the incidence of duplicative advanced imaging studies.

The ACR reported that proposed cuts in technical component of radiation therapy is mainly because CMS proposes to treat radiation treatment vaults as an indirect practice expense (PE) rather than direct PE. In previous rulemaking, CMS questioned whether it was consistent with the principles underlying the PE methodology to include the radiation treatment vault as a direct cost given that it appears to be more similar to building infrastructure costs than to medical equipment costs. CMS believes that the specific structural components required to house the linear accelerator are similar in concept to components required to house other medical equipment such as expensive imaging equipment. Therefore CMS believes that the special building requirements indicated for the radiation treatment vault to house a linear accelerator do not represent a direct cost in their PE methodology.  Accordingly, CMS proposes to remove the radiation treatment vault as a direct PE input from a list of 14 radiation treatment procedures.

As always, ADVOCATE will keep you updated on this and other issues impacting radiology as they become available.

Best regards,
Kirk Reinitz, CPA