Happy 4th to You Too, CMS

The recently released proposed rules contain both good news and bad news for radiologists


When I saw the tweet from @CMSGov on July 4, I couldn’t resist an eye roll.“Happy #July4th!” it said.

Happy for you, CMS staff, I thought. Not so happy for those of us whose inboxes started buzzing at 5 p.m. on July 3 with news that the proposed rules for 2015 had been issued. Emails and texts flew back and forth as we combed through the more than 1,200 combined pages of the Physician Fee Schedule and HOPPS Fee Schedule to see what changes were being proposed for our specialty. Thanks to our speed-reading staff and a laser focus, we were able to digest both reports and publish summaries for members on the website almost as fast as Joey Chestnut gobbled down 61 hotdogs to win his eighth straight Nathan’s Hotdog Eating Championship.

So will the proposed rules give you as much indigestion as the hot dogs gave the “Mustard Belt King”? All levity aside, these proposed rules contained fewer challenges than we have seen previously, but we still found many areas of concern.

Once again CMS did not extend the multiple procedure payment reduction to all imaging, which is a positive. But CMS has not yet complied with the legislative mandate that it publish its data and rationale for imposing the reduction in the first place. We sent a letter to CMS on June 17, 2014, requesting that it provide this data with all due haste.

The issue of changing the practice expense inputs in the payment formula from film to digital comprises the largest across-the-board potential cut. If CMS, as described in the proposed rule, removes all the inputs associated with a film environment and replaces them with a desktop computer, we would see significant reductions. Anyone who has installed or replaced a PACS system knows that this is simply ludicrous, and the Commission on Economics has had extensive communications with CMS to address this.

Once again, several of the services we provide were identified as fast growing, high expenditure, and targeted for future review. The review process has been riddled with flawed methodology, especially around the recognition of the amount of time rooms are in use. Since CMS continues to turn a deaf ear to our logic, we regard these future reviews with trepidation.

CMS has also decided it is time to retire the digital mammography G codes. In the short term, CMS proposes to pay the existing mammography CPT codes at the G code rates (150 percent of the analog rate). That’s good news, but CMS also wants to review those payment rates to see if they remain accurate. I don’t have to tell this audience how important it is to ensure our patients’ access to this life-saving service, so expect us to make a strong case to CMS that the current reimbursement should not drop.

And what is going on with tomosynthesis? You all know that CPT codes were created for tomosynthesis earlier this year by the CPT Editorial Panel. The new codes will be effective on January 1, 2015. Recommended RVU values for the codes were sent from the Relative Value Scale Update Committee to CMS. The values remain confidential until CMS finalizes them with the publication of the Final Rule, which comes out at the end of October. So the answer is, we don’t know yet. An FAQ was issued by CMS last November, strongly opposed by the ACR, stating that tomosynthesis is an integral part of the mammography service. This remains in effect until we learn what values are assigned for tomosynthesis and, very importantly, whether CMS will pay for the service. It’s important to remember that having a code and an RVU value is not a guarantee of coverage; just look at screening CT colonography.

On a bright note, we saw an egregious error corrected for the payment of the technical component of the new bundled breast biopsy codes in the hospital outpatient environment. This will result in a 51 percent increase in these payments. Unfortunately, this does not address the drastic reductions in the professional component payments. Our team has appealed the assigned value to CMS. We will know their decision upon publication of the 2015 Medicare Physician Fee Schedule Final Rule.

CMS walked away from a previous proposal to equalize payments across all sites of service after criticism from across the stakeholder spectrum. This topic remains of interest to CMS, so we will continue to monitor it. CMS is also interested in the impact of hospitals acquiring independent practices, on overall costs and out-of-pocket costs to beneficiaries. As we know, this has been an active trend in our specialty. In January, CMS plans to start gathering data on this trend using a modifier on the claim form.

In addition, CMS is asking for information on how, where, and why second interpretations are provided for imaging studies. It is looking into whether a change in payment policy might have a positive impact in reducing unnecessary repeat studies. I know this is a topic of great interest to all of us, and we would welcome your perspective. As always, you can reach me at This email address is being protected from spambots. You need JavaScript enabled to view it..
No matter what challenge we are faced with, your dedicated economics team will be working diligently to ensure that the reimbursements you receive for the valuable services you provide to your patients are fair and allow you to innovate and maintain the level of quality for which you strive. I encourage you to follow me on Twitter at @DrGMcGinty.


By Geraldine B. McGinty, MD, MBA, FACR, Chair

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