Economics Update
Medicare Physician Fee Schedule
The Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY)
2023 Medicare Physician Fee Schedule (MPFS) final rule Nov. 1. The ACR created a
detailed summary of provisions within the final rule that affect radiology and radiation oncology. CMS estimates an overall impact of the MPFS finalized changes to radiology to be a 2% decrease, while interventional radiology would see an aggregate decrease of 3%, nuclear medicine a 2% decrease, and radiation oncology and radiation therapy centers a 1% decrease. These reductions are less than the reductions in the proposed rule due to CMS correcting an error in the calculation of the malpractice relative value units (RVUs).
CMS finalized a CY 2023 conversion factor of $33.0607 compared to the 2022 conversion factor of $34.6062. This was calculated by first removing the one-year 3 percent increase provided by the Protecting Medicare and American Farmers from Sequester Cuts Act and then applying a negative 1.60 percent budget neutrality update. The budget neutrality update is largely related to increased values for several evaluation and management code families, including hospital, emergency medicine, nursing facility, and home visits.
If Congress does not intervene to extend the 3% increase provided by the Protecting Medicare and American Farmers from Sequester Cuts Act, the percent decreases mentioned above will be greater for CY 2023. The American Medical Association (AMA) estimates total decreases of 5 percent for radiology, 6% for interventional radiology, 5% for nuclear medicine, and 4% for radiation oncology and radiation therapy centers without Congressional action.
Hospital Outpatient Prospective Payment System
CMS increased the conversion factor by 3.8%, bringing it to $85.585 for CY 2023. There are no structural changes to the seven imaging ambulatory payment classifications (APCs), but the payment rates are modified. CMS modified the proposal to establish Healthcare Common Procedure Coding System (HCPCS) C-codes for Software as a Service (SaaS) procedures and instead will recognize SaaS CPT add-on codes and will pay separately for them.
Colorectal Cancer Screening
In a letter sent to the ACR in late June, the Centers for Medicare and Medicaid Services (CMS) denied an
April reconsideration request by the American College of Radiology® (ACR®) and five patient advocacy groups to expand Medicare coverage for National Coverage Determination (NCD) 210.3 for Screening Computed Tomography Colonography (CTC) for Colorectal Cancer.
CMS indicated that the additional evidence that was submitted is insufficient to support a reconsideration as it would not change the existing NCD. The ACR and the patient advocacy groups contend ample clinical evidence was provided to support coverage of this valuable preventive screening service. For more than a decade, Medicare beneficiaries have been denied access to CTC, while private payers and Medicaid expansion states have extended coverage after updates to the U.S. Preventive Services Taskforce (USPSTF) recommendation for colorectal cancer screening. The USPSTF endorsed CTC as a colorectal cancer screening option and expanded screening for colorectal cancer in all adults ages 45 to 75 years. As the Affordable Care Act requires private insurers to cover all USPSTF-approved screening services without patient cost-sharing, patients lose access to this screening option once they become Medicare age.
Members of the ACR’s Colon Cancer Committee as well as physician and staff leadership with the ACR met with CMS staff via Zoom in August to discuss the reason for the decision. Committee members passionately discussed healthcare disparities and how making CTC a screening option for Medicare beneficiaries reluctant to undergo a colonoscopy or stool-based test would greatly help minority populations get screened and ultimately would save lives. CMS continues to argue that there is not enough evidence specific to the Medicare population to support coverage.
The ACR included comments on CTC in its Medicare Physician Fee Schedule proposed rule comment letter and urged the Secretary to use his authority to immediately add CTC as a colorectal cancer screening option for Medicare beneficiaries.
