Proposed 2017 MPFS Published

It’s here! CMS has released the 2017 MPFS and ADVOCATE will be preparing a detailed analysis of the proposed rule in the coming weeks. In the meantime, we are providing the summary of all significant changes below.  The entire CMS document is published in the Federal Register.

2017 MPFS Reimbursement Changes

In 2015, Congress passed the Consolidated Appropriations Act of 2016, which included a provision that CMS lower the existing 25% professional component MPPR payment reduction to 5%, effective 2017. This reduction in the MPPR becomes effective January 1, 2017.

The 2017 conversion factor will be $35.75, which reflects the 0.5% update dictated by MACRA, a budget neutrality adjustment, and a 5% adjustment due to the reduction in the MPPR for the professional component of imaging services. The new conversion factor is slightly decreased from the current factor of $35.80.

Overall payments will decrease by 1%. By specialty it’s a different story, with interventional radiology seeing a steep cut due to CPT code restructuring and revaluation of some high volume codes in the “misvalued codes” initiative. By imaging specialty, the reimbursement changes are:

Diagnostic Radiology                                -1%
Interventional                                         -7%
Nuclear medicine                                     0%
Radiation oncology                                   0%
Radiation therapy centers                        -1%

Mammography and CAD

Three new mammography codes will be implemented in 2017 that bundle mammography with CAD. These codes will be structured similarly to the existing mammography codes, with a code for unilateral diagnostic mammography, a code for bilateral diagnostic mammography, and a code for screening mammography. These new codes will replace the current codes used to report mammography (77055-77057) and CAD (77051 and 77052).

The good news here is that payments will not be reduced as a result. Meaning the reimbursement for each new 2017 code representing mammography and CAD is said to be equal to the combined reimbursement for two 2016 codes representing mammography and CAD

Clinical decision support

The requirement to use clinical decision support based on appropriate use criteria will begin in January 2018, rather than 2017, a move CMS announced this year and reinforces in this proposed rule. CMS has added a proposal that prices professional PACS workstations at $14,617, which will improve payments across more than 400 current procedural terminology (CPT) codes.

The Protecting Access to Medicare Act of 2014 (PAMA) directed CMS to develop an appropriate use criteria/clinical decision-support (AUC/CDS) program for advanced diagnostic imaging services including, diagnostic MR, CT, and nuclear medicine (including PET). This program was mandated to be implemented in January 2017, but last year the agency announced that this would be delayed. The new proposed rule suggests an implementation date of January 1, 2018.

CMS is also suggesting specific requirements for how CDS/AUC is reported, using a clinical decision-support mechanism (CDSM). This electronic tool built by companies such as National Decision Support Company will communicate appropriate use criteria information to clinicians and help them make appropriate treatment decisions. CMS plans to take applications from CDSM developers from the publication date of its final MPFS 2017 rule until January 1, 2017. Qualified CDSMs will be announced by June 30 of next year.

PACS pricing

In this proposed rule, CMS is carrying forward the 2016 MPFS rule’s pricing for the technical component of PACS workstations at $5,557. However, CMS plans to price the professional component of PACS workstations at $14,617. This change in valuation in the professional component of the PACS workstations will be applied to 426 radiology CPT codes.

CMS has previously valued the technical PACS workstation pricing in its CPT code reimbursement calculations.  However, CMS hasn’t previously included professional PACS workstation pricing in its CPT code calculations.

As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.

Best regards,
Kirk Reinitz, CPA