Economics Update
ACR Requests Your Assistance: AMA Survey
On July 31, your practice may receive a national survey from the American Medical Association supported by over 170 medical specialties, including the ACR, to collect data on physician practice expenses, last updated in 2006. Your individual data will not be shared. Your feedback is critical to providing accurate practice cost information to policymakers, including members of Congress and CMS, which could impact your Medicare Physician Fee Schedule reimbursements for years to come. We urge you and your practice to participate and fill out this survey to ensure that practice expenses and patient care hours for radiologists are accurately reflected.
Learn more.
ACR Provides Detailed Summary of 2024 Medicare Physician Fee Schedule Final Rule
The American College of Radiology® (ACR®) prepared a
detailed summary of the 2024 Medicare Physician Fee Schedule final rule released by the Centers for Medicare and Medicaid Services (CMS) on Nov. 2. The final rule indicates 32.74 PFS conversion factor in 2024, a $1.14 decrease from the 2023 conversion factor of $33.89. CMS also describes further changes to payment provisions and updates to the Quality Payment Program in the final rule. The finalized changes take effect Jan. 1.
The final rule indicates a 32.74 PFS conversion factor in 2024, a $1.14 decrease from the 2023 conversion factor of $33.89. CMS also describes further changes to payment provisions and updates to the Quality Payment Program in the final rule. The finalized changes take effect Jan. 1.
If you have questions, contact
Angela Kim, ACR Senior Director, Economics and Health Policy.
Discover Details of 2024 HOPPS Final Rule in Detailed ACR Summary
The American College of Radiology® (ACR®) prepared a
detailed summary of the 2024
Hospital Outpatient Prospective Payment System (HOPPS) final rule released by the Centers for Medicare and Medicaid Services (CMS) on Nov. 2. The summary outlines issues that impact radiology, including updates to imaging ambulatory payment classifications and requirements for the Hospital Outpatient Quality Reporting program.
CMS finalized the update to HOPPS payment rates for hospitals that meet quality reporting requirements by 3.1%, increasing the conversion factor for calendar year 2024 to $87.382. CMS thanked stakeholders for their comments regarding the reimbursement of diagnostic radiopharmaceuticals and will further consider their feedback on potential policy changes for future notice and comment rulemaking. The agency also finalized updates to hospital price transparency policies with phased-in implementation.
The rule changes will be effective Jan. 1.
If you have questions, contact
Kimberly Greck, ACR Senior Economic Policy Analyst.
CMS Finalizes Pause to Imaging Appropriate Use Criteria Program
Providers Urged to Continue Use of Clinical Decision Support
The Centers for Medicare and Medicaid Services (CMS) proposes in the
2024 Medicare Physician Fee Schedule (MPFS) rule to pause the implementation of the Protecting Access to Medicare Act (PAMA) imaging appropriate use criteria (AUC) program. CMS continues to have concerns with the real-time claims processing aspect of the statute, stating “…we have exhausted all reasonable options for fully operationalizing the AUC program consistent with the statutory provisions…” The proposal says more time is needed to reevaluate the program to ensure that imaging claims are not inappropriately denied.
The American College of Radiology® (ACR®) recognizes the significant issues CMS faces with the real-time claims processing aspect of the AUC program and the potential impact on members if claims are denied inappropriately. The College is working with Congress to streamline and modernize the PAMA AUC program, including the removal of the claims-based reporting requirement, to allow the program to move forward and ensure Medicare patients receive the right imaging tests at the right time. The rule states that a fully implemented program could result in potential savings to the Medicare program of up to $700 million annually. An independent analysis by The Moran Company estimated the AUC program savings at a smaller, but still significant $2 billion over 10 years.
Despite the implementation barriers necessitating the reevaluation of the program, CMS recognizes the value of AUC to improve utilization patterns for Medicare beneficiaries in the proposed rule. The agency indicates that utilizing AUC to ensure that patients receive the right imaging at the right time would “inform more efficient treatment plans and address medical conditions more quickly and without unnecessary tests.” The rule states that this could result in potential savings to the Medicare program of $700 million annually.
Despite the implementation barriers necessitating the reevaluation of the program, CMS recognizes the value of AUC to improve utilization patterns for Medicare beneficiaries. The rule states, “We want to acknowledge and emphasize the value of clinical decision support to bolster efforts to improve the quality, safety, efficiency, and effectiveness of health care. We welcome and encourage the continued voluntary use of AUC and/or clinical decision support tools in a style and manner that most effectively and efficiently fits the needs and workflow of the clinician user. Across many specialties and services, not just advanced diagnostic imaging, clinical decision support predates the enactment of the PAMA and, given its utility when accessed and used appropriately, we expect it to continue being used to streamline and enhance decision-making in clinical practice and improve quality of care."
CMS states multiple times within the final rule that they will “continue efforts to identify a workable implementation approach and will propose to adopt any such approach through subsequent rulemaking, including implementing any amendments Congress might make.”
The PAMA imaging AUC program, passed by Congress and signed into law in 2014, requires ordering providers to consult AUC developed by provider-led entities through a clinical decision support mechanism when ordering advanced diagnostic imaging, including CT, MR, PET, and nuclear medicine, for Medicare Part B patients. It was designed as an alternative to prior authorization to decrease inappropriate imaging. If the program were to be fully implemented as currently written in law, payment for imaging services that do not contain the appropriate AUC consultation information on applicable claims would be denied. The program has been operating in an “educational and operations testing period” without payment penalties in place since Jan. 1, 2020. The decision to pause the program includes pausing the ongoing educational and operations testing period, effective January 1, 2024. ”
For more information, contact
Katie Keysor, ACR Senior Director, Economic Policy.
ACR Releases Detailed Summary of Pros and Cons in IDR Proposed Rule
The U.S. Departments of the Treasury, Labor, and Health and Human Services released a proposed rule on Oct. 27 outlining rules related to the federal independent dispute resolution (IDR) process initiated by the No Surprises Act (NSA).
The American College of Radiology® (ACR®) prepared a detailed summary of the provisions of the rule with the greatest impact on radiology. The College is encouraged that the departments recognize and propose policy changes to address concerns raised about imaging providers’ access to the IDR process. Specifically, the proposed rule would: provide expanded batching regulations, reduce the administrative fee for low-dollar claim disputes, and require insurers to provide claim eligibility information with initial payments. These are positive changes recommended by many specialty societies, including ACR. The College still has concerns with some details within the proposed rule, including limiting batching to 25-line items in a single dispute.
The government focused the proposed rule on streamlining the IDR process to make it more efficient and avoid backlogs. One of the most burdensome aspects of IDR is determining claim eligibility. The departments propose requiring more meaningful engagement by all parties in the open negotiation process.
ACR will submit comments on the rule during the comment period. For more information or if you have questions, contact Katie Keysor, ACR Senior Director of Economic Policy.
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