Economics Update
Radiology Practice Participation Urgently Needed in AMA Survey to Help Update Practice Costs
Last summer the American Medical Association supported by over 170 medical specialties, including the ACR, sent a national survey to collect data on physician practice expenses, last updated in 2006. Your 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 Supports Proposed Changes to Surprise Billing Act Independent Dispute Resolution Operations
The American College of Radiology® (ACR®) provided comments Dec. 22, in response to the U.S. Departments of the Treasury, Labor, and Health and Human Services proposed rule related to the federal independent dispute resolution (IDR) process initiated by the No Surprises Act (NSA). The College supports many proposed policy changes to address concerns raised about imaging providers’ access to the IDR process.
Specifically, the proposed rule addresses the failure of payers to communicate IDR eligibility information with payment remittance, financial accessibility of IDR for radiology practices, open negotiation communication issues, cooling-off period concerns, and IDR entity selection issues. The rule also includes a proposal to reduce the administrative fee for low-dollar claim disputes. These are positive changes recommended by many specialty societies, including ACR. While supporting the proposed changes, the ACR encouraged the departments to consider enforcement mechanisms for payers who do not comply with the statute and regulations.
The College expressed concern with some details within the proposed rule, including limiting batching to 25 line items in a single dispute, and details of the proposal to reduce the administrative fee for low-dollar claims. Imaging services are frequently significantly less than the $150 administrative fee required to be paid to enter the IDR process. Without the ability to submit comprehensive batches, IDR is not economically accessible for the majority of imaging claims. The ACR argues that since certified IDR entities are already permitted to charge additional fees for batches larger than 25 line items, batch limits are unnecessary. Similarly, ACR commented that the proposed reduced administrative fee for low-dollar claims of 50% of the full administrative fee is too high and recommended a reduced administrative fee of no more than $50.
ACR will submit comments on the rule during the comment period. Contact
Katie Keysor, ACR Senior Director of Economic Policy for more information.
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.
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